Cut on the bias

We’re all biased – there’s no getting away from it.  My own particular unfair bias is against taxi drivers; as a cyclist I have been sworn at, side-swiped and (once) squeezed with my bike against the back of a lorry in a queue of traffic by enough taxi drivers to make me mistrust the lot of them.  But as I write this I know it’s unfair.  A few months ago I was on a Boris bike in Marylebone and I was lost; cycling the wrong way up a one-way street I came wheel to bonnet with a black cab.  I steeled myself for the (in this case, justified) abuse but I could not have been more wrong: the driver wound down his window, asked whether I was lost (must have seen the sheer panic on my face) and gave me careful directions and a jolly wave as I set off.  And yet, and yet… I’m still not keen on cabbies.

By now you’re wondering how on earth I am going to haul this around to AML, but hold on tight because here we go: we need to be aware of our own biases when doing due diligence checks and risk assessments.  We all have our own cognitive bias – a built-in tendency to assess information in a certain way.  And from an AML perspective, two flavours of cognitive bias are particularly dangerous.  Confirmation bias means that once we have made up our mind on a subject (taxi = t***er), we tend to notice only information that confirms that view (squished against lorry) and discard anything that contradicts it (charming fellow in Marylebone).  And in order to make a fair assessment, you should of course take all information on face value and put it into the mix – whether it supports your much-cherished view or not.

Alongside this we have availability bias.  When asked to judge whether something is true or not, we often make our decision based on how easily examples (or counter-examples) come to mind, and not on a full assessment of all possible examples.  In the AML sphere, let’s take corrupt African leaders.  I bet you can name five without even breaking a sweat.  Given a little longer and a plate of Jaffa Cakes, I bet you could get to a dozen – spoilt for choice, shooting fish in a barrel, etc..  But have you heard of the Ibrahim Prize for Achievement in African Leadership?  Founded by Sudanese-born mobile phone magnate Mo Ibrahim, the award recognises “recognises and celebrates African executive leaders who, under challenging circumstances, have developed their countries and strengthened democracy and human rights for the shared benefit of their people, paving the way for sustainable and equitable prosperity”.  And now that you know that (and without following that link – I’m on to you) , can you name five previous winners?  Go on then, two?  (I’m insisting on two, because Nelson Mandela is just too easy – and yes, he won an award in 2007.)  Tricky, isn’t it – because the press rarely reports good, honest African leaders when the bling-y ones are so much more fun, with their gold-plated bath-taps and cellars of three hundred bottles of Chateau Petrus.  But in the spirit of full disclosure – after all, full disclosure is the enemy of availability bias (and there’s a winning slogan for your holiday t-shirt) – I should say that although Ellen Johnson Sirleaf of Liberia won an award in 2017, “in 2009, 2010, 2012, 2013, 2015 and 2016 the [Ibrahim] Prize Committee, after in-depth review, did not select a winner”.

So what can we AML-ers do to guard against our own bias?  Top tips:

  • When gathering due diligence information, don’t discard it as you go – something that seemed irrelevant at the time might become much more significant later in the process, so save it all to make an informed overall judgement
  • Encourage active questioning and constructive dissent to solicit a wide range of views
  • Show your findings to someone who is prepared to play devil’s advocate, particularly if you fear you might be too close to the situation to assess it objectively
  • Read and learn widely: the more balanced and deep knowledge you have, the less likely you are to fall unwitting victim to bias.
Posted in AML, Due diligence, Money laundering | Tagged , , , , , , , , | 2 Comments

The plain un-SAR-nished truth

Remember when Hugh Grant was PM in “Love Actually” and he found out that his tea-lady’s ex-boyfriend had been nasty to her and offered to have the scoundrel assassinated by the “absolutely charming” SAS?  “Ruthless trained killers are just a phone call away”, he tells her.  This comes to mind as I prepare to criticise the National Crime Agency – although only the FIU bit of it, and I’m hoping they’re not routinely armed.

The SARs regime has come in for a fair bit of bashing recently, not least in the FATF’s mutual evaluation of the UK’s AML efforts.  And for several years now we have been promised an overhaul of the SARs regime.  But the thing I want to mention today is the NCA’s cowardice *checks behind her for ruthless trained killers*.  I mean specifically their cowardice when it comes to rapping the knuckles of those who submit poor quality SARs, or no SARs at all.  I’ve been re-reading the NCA’s SARS annual reports, and in 2015 they said: “The UKFIU makes no comment as to the relative volume of reports from different sectors.  It is for the sectors and their supervisors to assess if the volume of SARs submitted is proportionate to the risks their sectors face.”  In 2017 they said: “The UKFIU makes no comment as to the relative volume of reports from different sectors.  It is for the sectors and their supervisors to assess if the volume of SARs submitted is proportionate to the risks their sectors face.”  And in 2018 they said: “The UKFIU makes no comment as to the relative volume of reports from different sectors.  It is for the sectors and their supervisors to assess if the volume of SARs submitted is proportionate to the risks their sectors face.”  Apart from showing a mastery of the cut and paste technique, this is disappointing.

Let’s be honest: no AML supervisory agency is going to say that they are worried by the low level of reporting in their sector, because that will reflect badly on them.  In the FCA’s “AML Annual report 2017/18” they have one pie chart which illustrates that 922,544 internal SARs were reported to MLROs within firms – no accompanying comment on whether this is proportionate to the money laundering risks faced by their supervised population.  In the Solicitors Regulation Authority’s “Annual Review 2016/17” they tell us that “the NCA received 4,878 reports from independent legal professionals from October 2015 to March 2017 [and] we anticipate we will see more in the coming year”.  And I can’t find anything from any of the other AML supervisors – which may be my failing, but if it’s out there, it’s well hidden.

I turn to the UK’s National Risk Assessment 2017, which goes further than anything else I have seen, but still treads gently.  With regard to accountants, “the 2015 NRA assessed that the number of SARs submitted by the accountancy sector was relatively low, and numbers have continued to decline”.  As for lawyers, “the 2015 NRA assessed that the number of SARs submitted by the legal sector was relatively low, and numbers have declined since that stage”.  You can almost see them shaking their heads in sorrow at the Home Office and HMT.

So if the NCA (who surely could be seen as independent and not favouring one sector over another) won’t venture an opinion along the lines of “how can it be that all the estate agents in the whole of the UK noticed only 710 dodgy things in the period April 2017 to March 2018 – fewer than were noticed by cheque cashers, or bookmakers, or those involved in spread betting?”, and nor will the AML supervisors, or even those responsible for compiling the National Risk Assessment, exactly who is going to call it?  Submitting SARs is not just a paper exercise that can be shunted down the queue when something more interesting/profitable comes along.  We’re up against real ruthless trained killers, and people traffickers, and child pornographers, and terrorist financiers – and to battle them we need to stop worrying about hurting the feelings of those who aren’t doing their SAR duty.

Posted in AML, Money laundering, Organised crime, Supervision | Tagged , , , , , , , , , , , , | 8 Comments

Cleaning house

Last week I attended an event at the elegant Whitehall premises of RUSI at which they launched “No Rest for the Wicked”, their report into what the UK’s next steps should be, now that we have (to quote the modest press release from the Treasury) “taken top spot in the fight against money laundering”.  Top spot, that is, in the eyes of the FATF – and it is important to remember that the FATF looks at things from on high, concentrating on legislative regimes, supervisory structures and international co-operation.  They do not concern themselves with (as a French friend of mine so charmingly has it) the nitties and the gritties of everyday AML efforts, but rather with assessing the framework within which the nitties and the gritties can be performed.

The RUSI report – which I recommend – clarifies the three areas in which the UK, despite its top spot, did not receive a ringing endorsement: the use of financial intelligence (basically, we’re not squeezing enough goodness from SARs); the supervisory regime (which dreams of being as structured as a dog’s dinner); and the international laughing stock that is Companies House.  As the FATF mutual evaluation report from December 2018 notes with admirable restraint, “beneficial ownership information on the People with Significant Control (PSC) register is not verified and there are limited screening checks”.  Personally, I would have put it thus:  I have written before about this embarrassing shortcoming: what on earth is the point of telling MLROs (in the UK and elsewhere) to check the CH database for company ownership information if a company can submit whatever garbage it wants to CH, secure in the knowledge that no-one will verify it?  Will we soon see a hapless MLRO doing the required due diligence checks, carefully saving a printout of the CH entry for the entity he is researching, making a reasoned risk assessment based in part on this information – and then coming a cropper when an investigator tells him that everyone knows that CH is an unreliable source?

But it seems that things may be, finally, creakingly, on the move at Companies House.  In answer to a written question on 19 February 2019, Economic Secretary to the Treasury John Glen confirmed that “a broader package of reforms to Companies House will be consulted on later this year”.  Given that the UK government is planning for an additional new register – of overseas companies that own property in the UK – to come live in 2021, we need to get a move on.  And of course, in time-honoured, finger-wagging fashion, the UK has already passed the Sanctions and Anti-Money Laundering Act 2018, which requires that “the Secretary of State must, no later than 31 December 2020, prepare a draft Order in Council requiring the government of any British Overseas Territory that has not introduced a publicly accessible register of the beneficial ownership of companies within its jurisdiction to do so”.  I’m no apologist for OTs that do AML on the cheap but even I can see that this is a bit of a cheek (unless we really would be content for an OT to set up a BO register that is just as toothless as ours).  To reap what the RUSI chap so eloquently called the “diplomatic dividend”, we do need to get our own Companies House in order, and sharpish.

Posted in AML, Due diligence, Money laundering | Tagged , , , , , , , , , , , , | 4 Comments

Money launder-gig

I’m always surprised – although I try not to show it – when people ask me how money laundering actually works, as there is an almost infinite number of ways in which criminals can move their money around.  Invent a new product or initiative, and within about twenty seconds the money launderers will be picking it apart to see how they can abuse it.  Witness the recent stories about criminals using Uber and Airbnb to launder their funds.

I have never used Uber (I know! Crazy! I love bicycles and trains!) but I am a dedicated fan of the Airbnb mini-city-break (with chocolate).  And I have wondered before about the fairness (and indeed safety) of a scheme that allows people to – in effect – run little hotels without having to bother with any of the tedious stuff that proper hotels have to do (fire escapes, checks on staff, booking guarantees, etc.).  But I will admit that I had not thought of the gig economy specifically as a money laundering risk – fool that I am.

This is how the system of “ghost rides” works on Uber:

  • The criminal recruits a dodgy Uber driver looking to make some easy money via the dark web
  • The driver pretends to take the criminal on a taxi ride
  • The criminal of course does not show up but pays for the ride with a stolen credit card
  • The Uber driver host keeps some of the money and wires the rest back to the criminal.

One variant of the Uber scheme is known as “acupuncture” because it involves a criminal overseas – usually in China or India – colluding with a driver by dropping location “pins” in the Uber application along the driver’s regular route.  The driver collects the fares as though he had really picked up passengers and then wires most of it back to the overseas criminal, known as the “nurse”.

As for Airbnb, hosts will answer ads on the dark web.  (For the scheme to work well, without arousing the suspicion of Airbnb, they should ideally be established hosts with a track history and good feedback.  But of course some such people do fall on hard times and are ripe for exploitation.)  Instead of hosting an actual guest, they simply take payment from a fake guest who never has any intention of showing up.  Once the payment is processed through Airbnb, the host refunds a portion of the nightly bill to the criminal who has recruited him – and who takes care to leave a positive review to satisfy Airbnb and to keep the host in business.  The only thing the host is laundering is money – no sheets or towels.

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The Brexit bonanza for baddies

You have probably guessed from recent tear-stained posts that I am not a fan of Brexit.  Having lived an international life surrounded – very happily – by people from all over the world, I rear up at the thought of immigration controls.  Having lost five great-uncles to war, I am thankful every day for the seventy years of peace engineered by the EU.  And having seen the unbelievable shambles created by the UK parliament over the past two years, I would pay anything to give back control to Brussels.  But those are just personal preferences: my professional life is another matter.  And I think that most AML-ers are of the view that leaving the EU will prove a bonanza for those who wish to launder money through the UK.

For a start, if we leave the EU we will be drummed out of Europol.  This is bad enough for those law enforcement agents who have spent a career building up networks and alliances in the Europe-wide crime-fighting community, but it also means that we will be excluded from Europol’s database – the Europol Information System.  This is bursting at the seams with juicy information from all EU Member States, whose police forces can search it to find links and connections and relationships.  An investigator in the National Crime Agency in their secret London HQ (don’t tell anyone, but it’s in Vauxhall) can log onto the EIS and see whether their suspect has any financial presence anywhere in the EU, or whether he is sending money to an account in the EU, or whether his passport has been used as ID verification in a bank or airport or hotel in the EU.  Quite handy, you might think.  Of course there is talk of the UK negotiating apparently favourable information-sharing agreements with all of its EU neighbours individually but let’s be realistic: that’s going to take ages, we’ve not shown ourselves to be particularly skilled at such negotiations, and *stamps little feet* it won’t be anywhere near as good as being able to have a rootle around in the EIS.

Then there is our AML legislation.  At the moment we operate under the Money Laundering Regulations 2017, which are our domestic answer to the Fourth Money Laundering Directive.  This is, as far as I am concerned, Exactly As It Should Be.  MLD4 is not perfect, but no-one could accuse those involved in its creation of not exploring the subject, or not debating the issues, or not listening to all concerns, or not being prepared to run through several drafts.  And it presents a united front – which we know is anathema to criminals, who live to sniff out differences that they can exploit in international legislation.  When it comes to an international crime, you need an international approach – and MLD4 is certainly that.  According to the (as yet draft) Money Laundering and Transfer of Funds (Information) (Amendment) (EU Exit) Regulations 2018 – which will come into force if we leave the EU – things in the UK will continue in the vein of MLD4 for a while: “in the definition of ‘fourth money laundering directive’, at the end, insert ‘as it had effect on 26th June 2017’”.  But what then?  )You will notice that the amendment regs make no mention of the Fifth Money Laundering Directive, which supposedly we will be implementing.)  Will we – in the immortal words of Fleetwood Mac – go our own way?  Frankly, I feel a thousand times safer with AML legislation that has been considered, debated and drafted by an informed group of concerned representatives from EU countries than with whatever will be produced by the four people who are left in HMT after Brexit, charged with doing whatever it takes to keep the UK economy afloat.  “I know,” one of them might say, “let’s make the UK a more welcoming financial jurisdiction by cutting red tape, getting rid of all that EU-inspired due diligence nonsense, and opening the doors to overseas investors.”  Give me strength.  And now, if someone could give me a hand, I will clamber down from my soap-box.

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , , , , | 5 Comments

Adding some blacking to the UK pot

Any crime that generates money can lead to money laundering, but one of the biggies – and one of the most worrying for governments, with its reputational implications – is corruption.  We tend of think of high-level, regime-toppling corruption (naming no names, but come on – we’re spoilt for choice these days) but in terms of social harm, the best definition is the simplest: the abuse of public power for private gain.  This catches all magnitudes of corruption, from the politician who uses his power to line his own pockets to the traffic cop who pulls over motorists and issues on-the-spot fines for non-existent infringements – all are damaging to the fair operation of our economies and our communities.  And to help MLROs keep track of which jurisdictions are most tainted with corruption, and which are doing the most to combat it, we have the annual Corruption Perceptions Index published by Transparency International.

This year’s edition appeared on 29 January 2019; it “draws on 13 surveys and expert assessments to measure public sector corruption in 180 countries and territories, giving each a score from zero (highly corrupt) to 100 (very clean)”.  There is little change at the top (Denmark triumphs with 88 out of 100, while New Zealand, Finland, Singapore, Sweden and Switzerland follow close behind) or indeed at the bottom (Somalia, Syria, South Sudan, Yemen and North Korea all score less than 15 out of 100).

There is plenty of analysis to be done on the CPI – on TI’s own website, they offer several specific insights, including “Western Europe and EU: stagnating anti-corruption efforts and weakening democratic institutions”, “Americas: weakening democracy and rise in populism hinder anti-corruption efforts” and “Trouble at the top: why high-scoring countries aren’t corruption-free”.  Of course I am particularly interested in my own jurisdiction – the UK.  And we’re not doing as well as we might – which is surprising, when you consider how we are handling all other political issues with such panache.  (If Brexit happens, will words like panache and élan be outlawed?)

Looking at the bald figures, in 2015 and 2016 the UK scored 81 out of 100, and in 2017 we bumped that up to 82.  But in 2018 we went down to 80 – and thereby dropped out of the top ten in the ranking.  So what has gone wrong?  According to TI analysis: “Over the past year, the UK experienced a few public sector scandals involving Members of Parliament who were found guilty of taking undeclared holidays paid for by foreign states.  In addition, questions over the origin of money used in the EU referendum combined with concerns over the future of Brexit make future movement of the UK on the CPI unclear.”  We’re also mixing with some fairly unsavoury company, as Robert Barrington of the UK chapter of TI points out: “We also note the huge fall in rankings of Azerbaijan [from 31 out of 100 in 2017 to 25 out of 100 in 2018] whose President was in the UK just last year meeting with the British Prime Minister and whose ruling family owns a number of UK-based assets.  Although hosting corrupt kleptocrats in London does not affect the score on this index of public sector corruption, the UK government should be aware of the detrimental impact it has on the UK’s international standing.”  With all of that going on, I think we can count ourselves lucky to have stayed as high as we have in the index – I will hardly be able to look at the 2019 edition.

Posted in AML, Bribery and corruption, Money laundering | Tagged , , , , , , , , , , , | 2 Comments

Officer politics

One of my main arenas of AML activity is Guernsey, and life there is pretty exciting at the moment with the imminent arrival of new AML legislation and guidance – both already published and coming into force on 31 March 2019.  There’s plenty of meat on those particular bones but what I want to discuss today is the unveiling of the new Guernsey MLCO.  *Anorak alert: this post is for the nit-pickers amongst you.*

In the planning stages, there was talk of rebranding the MLRO in Guernsey as a FCRO – Financial Crime Reporting Officer.  I was against this development for various reasons (no-one else will know what it means; it would be an alarming development for officers who would find themselves held legally responsible for knowing about all financial crimes and not just money laundering and terrorist financing; and it’s a bugger for me to say during training sessions) and thankfully the whole idea was dropped somewhere in the drafting process.  Instead, the new set-up in Guernsey will be this: firms (now known as “specified businesses”) will be required to have a Money Laundering Compliance Officer, an MLRO and a Nominated Officer.

Now, it’s not a bad arrangement – and indeed the MLCO/MLRO double act has been used successfully for years in Jersey.  In short, the MLCO (and I’m quoting here from the shiny new Handbook on Countering Financial Crime and Terrorist Financing) “is to have responsibility for the firm’s compliance with its policies, procedures and controls to forestall, prevent and detect money laundering and terrorist financing”, while the MLRO (and this is from the legislation) is “nominated by a specified business to receive disclosures”.  And the Nominated Officer will “carry out the functions of the MLRO in that officer’s absence”.  The MLCO and the MLRO can be the same person, but obviously the MLRO and the NO cannot.  In short (Venn diagrams at the ready) you can have:

  • Three people: MLCO, MLRO and NO
  • Two people: MLCO/MLRO and NO
  • Two people: MLCO/NO and MLRO

My only small niggle with the new arrangement is that the Guernsey NO is not the same as NOs in other countries.  Under the UK’s Money Laundering Regulations 2017, for instance, the nominated officer is “a person who is nominated to receive disclosures” – i.e. it’s the actual legal term for the disclosing bit of the MLRO’s job.  (In the UK we don’t have an MLCO at all – the person who’s called the MLRO generally does the nominated officer stuff plus what Guernsey’s MLCO would do.)  And if you’re confused now, well, that’s my point: for firms operating across jurisdictions, it’s tricky when different job titles are used for the same work or – more dangerously for whoever has the title – the same title is used for different legal responsibilities.  Why didn’t Guernsey go for “deputy MLRO” rather than the more loaded Nominated Officer title?  Ah, the mysteries of legislators…

Posted in AML, Legislation, Money laundering | Tagged , , , , , , , , , , , , , | 3 Comments

On the campaign trail

Recently I was asked to provide some text to be considered for inclusion in an AML awareness campaign – I’m not sure yet whether my contribution has been accepted but I will let you know.  I was therefore already thinking about the benefits of such campaigns when I came across a news story from the other side of the world.  “More than $1 million splashed on New Zealand anti-money laundering billboards” was the headline, and it revealed that since 2017 the NZ government has spent NZ$1.083 million (that’s about £565,000) on an AML campaign called “Keep Our Money Clean”, with its own campaign website.  The timing is significant: the NZ AML family is being extended (lawyers, conveyancers and TSCPs came in on 1 July 2018, accountants on 1 October 2018 and estate agents on 1 January 2019, while HVDs and the NZ Racing Board will come in on 1 August 2019) and the campaign is intended to help those new entrants to educate their customers about the new AML obligations.

Not everyone is convinced that it has been money well spent.  Right-wing NZ politician David Seymour thinks that the coalition government (of which his ACT party is not a part – just saying) has concentrated on the wrong thing: “A smarter approach would have been to finalise the details of the AML laws earlier.  In reality, real estate agents only found out about the detail in November or December [2018].  They’re now reeling to get prepared, and a million dollar advertising campaign hasn’t helped matters at all.”  On the other hand, Justice Minister Andrew Little says that it has worked: “Getting information out about what is happening, and most importantly why it’s happening, is working.  I think the cost is pretty modest by comparison, and by and large the feedback is that it is doing what it was intended to do and  people are getting their heads around [the AML implications].”

AML campaigns – like all advertising initiatives – are interesting projects.  They need to be clear on their audience: are they targeting the regulated sector (like our “Flag It Up” campaign here in the UK) or the general public (like the – related – “Take Five to Stop Fraud” campaign)?  Or are they a hybrid, as the NZ campaign seems to be: designed to help the regulated sector explain AML to the general public?  Has any of you come across a particularly effective AML campaign – or perhaps an especially dreadful one?  And what do you think of the very idea of these campaigns?

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Laundering and llamas

The last time I played a game on a screen was in about 1980, when my friend and I discovered the joys of Pong – that table-tennis-ish game with two bats (OK, white lines) that you moved up and down the court (OK, black screen) to hit the ball (OK, white square) between you.  And I do not have teenage children.  In all, I am therefore probably not best placed to talk about the intricacies of Fortnite, which Wikipedia tells me is an online game that comes in “three distinct game mode versions that share the same general gameplay and game engine: Fortnite: Save the World, a co-operative shooter-survival game for up to four players to fight off zombie-like creatures and defend objects with fortifications they can build; Fortnite Battle Royale, a free-to-play game where up to 100 players fight to be the last person standing; and Fortnite Creative, where players are given complete freedom to create worlds and battle arenas”.  Crucially, they use “V-bucks, in-game currency that can be purchased with real-world funds, but also earned through completing missions and other achievements in Save the World.  V-bucks in Save the World can be used to buy piñatas shaped like llamas to gain a random selection of items. In Battle Royale, V-bucks can be used to buy cosmetic items like character models, or can also be used to purchase the game’s Battle Pass, a tiered progression of customization rewards for gaining experience and completing certain objectives during the course of a Battle Royale season”.  Yes, that’s piñatas shaped like llamas.  Despite (or perhaps because of) this obvious lunacy, Fortnite is a huge success: free to play on a variety of gaming platforms, it has already drawn in over 200 million players.

But all is not well in the world of Fortnite and its V-bucks.  From news stories all over the world in recent weeks, we learned that criminals are using Fortnite for laundering: they use stolen credit cards (and stolen identity details) to purchase V-bucks from the Fortnite store and then resell them on the dark web.  An investigation conducted jointly by The Independent and cyber security firm Sixgill uncovered “discounted V-bucks being sold in bulk on the dark web as well as in smaller quantities on the open web by advertising them on social media platforms like Instagram and Twitter”.  The investigation came across “operations being conducted around the globe in Chinese, Russian, Spanish, Arabic and English”.  According to Benjamin Preminger, a senior intelligence analyst at Sixgill: “Criminals are executing carding fraud and getting money in and out of the Fortnite system with relative impunity… Epic Games [the developer of Fortnite] doesn’t seem to clamp down in any serious way on criminal activity surrounding Fortnite, money laundering or otherwise.  While completely stopping such criminal activity is extremely difficult, several steps could be taken to mitigate the phenomenon, including monitoring the transfer of high-value goods in the game, identifying players with large stockpiles of V-bucks, and sharing data with relevant law enforcement agencies.”  So he’s suggesting collecting client identity details, monitoring their transactions and reporting suspicious activity – where have we heard that before?

Posted in AML, Money laundering | Tagged , , , , , , , , , | 1 Comment

Taking task forces to task

May I be honest with you?  I have worked alone for more than twenty years and I like it, I really do.  As an only child I became used to not having to compromise, and I also have a visceral loathing of meetings, so running a one-person business where I make all the decisions and don’t have to take anyone else’s opinions into account suits me well.  But in my little AML-ish heart I have an unfulfilled ambition: I long to be part of a strategic consultative body.  I dream (sometimes literally…) of someone from the Treasury phoning me up and saying, “You’ve been doing this AML stuff for a while now, and your perspective on how MLROs actually deal with it is just the angle we need to complete our task force – are you free on Wednesday?”.  Ah, let me just pause and imagine that for a moment….  OK, I’m back now.

It has, of course, never happened.  I once felt that I knew a chap from the Treasury well enough to ask him, without sounding pathetic and needy (well, perhaps just a bit), why I’m always left on my own in the playground when it comes to picking task force teams.  And he said that it’s my very independence that does for me.  Because I don’t represent any specific group of people – I’m not from the BBA or the ICAEW or the Law Society – there’s no place at the table reserved for me.  And frankly, it’s too late in the day for me to hitch my AML wagon to any particular trade body – I like dealing with everyone.  So here I stand, nose pressed against the window, watching the launch of yet another AML task force to which I was not invited *sob*.

On 14 January 2019 it was announced that the (UK) Home Secretary and Chancellor will jointly chair the Economic Crime Strategic Board, which will meet twice a year to “set priorities, direct resources and scrutinise performance against the economic crime threat… set out in the Serious and Organised Crime Strategy”.  There are some top people involved: “The board includes CEOs and chief executives from the banking institutions Barclays, Lloyds and Santander as well as senior representatives from UK Finance, the National Crime Agency and the Solicitors Regulation Authority, Accountants Affinity Group and National Association of Estate Agents.”  Their first two pieces of business will be to approve both an investment of £3.5 million “to support work to reform the SARs regime” and “additional investment in the multi-agency National Economic Crime Centre”.  As ever, I am disappointed to see that there is no-one at the table talking on behalf of the MLROs who have to implement whatever economic crime strategy trickles down to the front line (and be held responsible for its success or failure).  If only we knew someone who works with MLROs in all sectors and hears their practical difficulties and suggestions on a daily basis…

Posted in AML, Money laundering | Tagged , , , , , , , , , , | 6 Comments