And so here we are: my final weekly blog post. I could think of no more fitting topic than my top five tips for MLROs, garnered over twenty-five years of working with you.
- Get people to care. It’s all very well reminding staff about the legislation and penalties, about your policies and procedures, but we all know that no-one works to their highest standard unless they care about what they’re doing. So tell them about people trafficking and drug overdoses and the sale of child pornography and the poaching of wild animals and the theft of state assets and how their tax bills are higher because so many people are evading their obligations. And explain that money laundering is the crime that allows all other crimes to flourish – and that AML is our best weapon against it.
- Tell them stories. Yes, I know your staff and directors are all grown-ups, but we all love a good story. So research the latest money laundering convictions – particularly those that involve your sector and your type of clients (and you know there will be some) – and turn the bland details into an exciting tale of the triumph of AML (or at least, the triumph of money laundering investigation) over the forces of evil.
- Record everything. We all agree that the risk-based approach is the most sensible, as it allows you to vary your AML according to the risk presented, but the price you pay for that is that someone in the future could question your decisions. Did you assess the client correctly? Did you put them into the right CDD category – and was that CDD applied without fear or favour? To protect yourself, record it all: every client interaction, every search for corroboration, every deliberation, every decision. Drum it into your staff that file notes are an essential part of it all – not just filling in the standard forms.
- Meet other MLROs. You may be the only MLRO in your firm. But even if you are lucky enough to have a compliance team around you, so that you can bounce ideas around and discuss tricky situations, you will only be seeing things from the perspective of your own firm and your own sector. Join MLRO groups so that you can meet others and see the problems and solutions from a different angle. They may well have already cracked the vexatious issue with which you have been wrestling. Which leads me to my final tip…
- Be generous. Give freely of your time and your expertise. When I started out in AML – in the early days of the Industrial Revolution – I was quite guarded about “giving away” my information. But then my natural blabbermouth emerged and I discovered – miraculously – that the more I shared, the more I was given in return. I would email someone a relevant news story – and a month later they would send me a copy of an expensive industry report. I would take a quick look at someone’s AML policy – and a year later they would commission me to rewrite their whole manual. But don’t just do it for what you can get out of it: we’re an AML community, and it’s only by co-operating and sharing that we will succeed (and enjoy it while we do).
And one very last observation, if I may. When people say to you (and they will) “but what’s the point of AML – as long as there’s money there will be crime and money laundering”, just remember this. For everything in life you have only two options: do something or do nothing. Doing nothing in the face of money laundering was never possible for me – nor, I assume, for you – and genuine effort is never wasted. If you have made life awkward for even one criminal, if you have blocked even one penny of criminal proceeds from moving through the financial sector, you have done more than most people and that’s a triumph. I salute you all.
I will be uncharacteristically brief – thank you!
As will I: you’re more than welcome!
Very best wishes to you, and thank you for all the smiles
Thank you, Kevin – it was a pleasure. Best wishes from Susan
Before you go galloping off into the soaking wet Cambridgeshire sunset, I just wanted to thank you for all that you have done for us, and for me. Your training sessions were a wonderful mix of very serious reminders of this vast problem that we deal with on a daily basis, and humour, without which I have always found learning difficult! There are very few educators in this area that can inspire and enthuse as you can and you will be sorely missed. Please keep writing your books, cycling, sipping good reds and occasionally think about us poor souls battling on, but only very occasionally. With all good wishes for a happy and healthy future, David.
Thank you for your very kind wishes, David – as I say, the trick to getting good work from people is to make them care, and I always cared very much. Best wishes from Susan
Thank you Susan for your informative and entertaining blogs which I have very much enjoyed reading.
You have shone a beacon of light on the importance of MLROs and how we can enable businesses to assist us in the fight against money laundering. It is never going to be the sexiest job in the workplace and I work hard at keeping a sense of humour, so that the human element of what I do is not overshadowed by the quotation of laws and regulations (which seem to increase year on year!)
I wish you all the best.
âNathalie Pike Head of Compliance, Guernsey Let’s talk… t. +44 (0) 1481 739488 I am based in Guernsey Watch our brand film at sannegroup.com
You are so very welcome, Nathalie – it has been such a wonderful career for me that it hardly seemed like work. It may not be the sexiest job, but boy, is it important! Best wishes from Susan
Couldnât agree more.
Best wishes for the future
Ian Spence â Head of AML / CFT â AML/CFT Division
Isle of Man Financial Services Authority
PO Box 58 â¢ Finch Hill House â¢ Bucks Road â¢ Douglas â¢ Isle of Man â¢ IM99 1DT â¢ email@example.com Tel: 01624 689328
Thank you, Ian – that means a great deal coming from a regulator of your standing. Best wishes from Susan
On Wed, 29 Dec 2021 at 10:38, I hate money laundering wrote:
Will miss your regular blogs
Happy new year
> ihatemoneylaundering posted: ” And so here we are: my final weekly blog > post. I could think of no more fitting topic than my top five tips for > MLROs, garnered over twenty-five years of working with you. Get people to > care. It’s all very well reminding staff about the legisla” > I
As will I, Richard – it’s going to be a hard habit to break! Best wishes from Susan
I have never responded to your blog posts but always read them with relish over the years! They have been a rare mix of generous information, intellect, wit and humour. You have such a way with words… I am sure there are many like me who loved reading your posts but never posted a response. Thank you for all you have contributed to the AML community! You will be missed. Wishing you a healthy, peaceful and fulfilled future.
Thank you for your kind words, Kwansema – I am delighted to hear that my posts have been helpful and enjoyable. I’m going to miss my weekly rant! Best wishes from Susan
Susan, as a weekly reader of your informed and witty articles, I would like to say thank you for all you have done for MLROs and the AML community, and I would like to wish you a very happy retirement.
Dear Stuart, that is so very kind of you – I’m going to miss it all very much. Best wishes from Susan
Thank you for all the work you have done in raising AML as an issue that affects all of us, in one way or another. Your AML books have always been one of my favourite methods to let staff know what they are meant to know – in a very easy to understand format. Enjoy your retirement – your contribution to the good fight will be missed. Peter
Dear Peter, you are more than welcome – I have been so lucky to have had such a fascinating and fulfilling career, surrounded by people who are determined to fight that good fight. Best wishes from Susan
Thanks for all the info and stories over the years. Very sorry that you have decided to retire, but I hope you enjoy it.
You are very welcome, Trevor – and it’s such a fascinating and important subject that I am sure someone else will pick up the baton. Best wishes from Susan
Thank you for your last post. And all the ones before this one. I just want to say that I have enjoyed reading them over the course of several years and also learned quite a lot from you, as I am used to be more focused on anti-corruption than on AML. But well, the two go hand-in-hand so at a given moment I decided I had to learn something about AML as well. It is a shame to see you leave the profession, but I hope that you will find other challenging and rewarding endeavors. All the best in 2022 and for many, many more years to come! And many Jaffa cakes!
Kind regards, Geert Vermeulen ________________________________________ ECMC: Ethics & Compliance Management & Consulting Geert Vermeulen
R.H. Fledderusstraat 17 3071 MH Rotterdam The Netherlands T: +31 6 52884699 E: firstname.lastname@example.org W: http://www.ethicscompliancemc.com
Chamber of Commerce Rotterdam no 64842258
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Dear Geert, thank you so much for your kind words – international readership! Yes, I am afraid that corruption seems to be growing rather than shrinking, not least in my own jurisdiction. And yes, Jaffa Cakes will continue to feature… Best wishes from Susan
Hi Susan, Like the commentators above I have much enjoyed your wit and wisdom and wish you a very busy retirement. Best wishes, Tristram
I plan to recline on a chaise longue and inhale Jaffa Cakes.
Hi Susan I’ve very much enjoyed your blogs over the years and the firm your training. You have brought a unique perspective to the AML community and it will be much missed. Wishing you all the best for the next chapters. Donna
Hi Donna, it has been a pleasure to work with you over the years – our pub lunch in Leadenhall Market remains a highlight memory! Best wishes from Susan
Thank you, Susan! I will miss your informative and entertaining blogs but all good things must come to an end. Thanks again and very best wishes, Jane
Dear Jane, thank you for your kind words. It’s strange not checking money laundering stories first thing every day, but my blog archive will remain for future AML-ers. Best wishes from Susan
Well done for everything Susan. I think your final paragraph firmly trumps my cynicism over the usefulness of the compliance ‘industry’.
Many thanks, Roy. And yes, there is much to criticise about compliance, but on balance, I think it is both necessary and effective. But then I would say that, wouldn’t I! Best wishes from Susan