Susan has been making her living from crime for over twenty years. She provides anti-money laundering training and advice to the regulated community in the UK, Guernsey, Jersey, the Isle of Man and Gibraltar, and writes and talks on the subject at every opportunity. As her hobby she writes historical novels – about financial crime.
Now that results are in for my little AML survey, let’s take a look at responses to the first question: why you do what you do. The wording of the question was: “Being totally honest, please (remember, this is anonymous!): what drives you personally to comply with the AML regime of your organisation?” I then gave eight options and space for people to suggest “other” drivers.
The most popular driver – by a whisker, with 173 of 215 respondents selecting it – was “I think that criminals should not be able to profit from their crimes, and AML is one weapon we can use against them”. I should confess that this is my own personal top choice, which means either that I am less of a freak than I had thought, or that I draw like-minded people to myself and to my blog. Either way, I’m delighted to hear it. In second place – with 166 of the 215 choosing it – was “I want to protect my organisation from infiltration by criminal money in order to protect its reputation”. Interestingly, protecting their organisation’s reputation was more important to respondents than preserving its licence (which garnered only 140 selections) . And indeed reputational concern was wider than that: 159 of the 215 chose “I want to protect my own reputation”. In today’s more connected world, and with many respondents working in smaller jurisdictions (as revealed last time), it is clear that they realise that being associated with money laundering is a definite brake on the career.
The legal drivers were much less scary than I thought they might be: only 53 people chose “It is a contractual obligation of my job”, and only 25 went for “I do it only because I have to – it is a legal requirement”. It seems that when it comes to the AML-devoted, the carrot is very much more effective than the stick.
And what of the freeform “others”? When given licence to vent, what did people confess made them do their AML duty? I’m glad to read that I am not the only AML-obsessive in town: “AML/CTF is very interesting and helps to stop global crime”; “AML and criminality go hand in hand: convict them of a lifestyle offence, then take their assets away from them – it hurts them more than any sentence”; “It’s my vocation and I love it”; and “I love AML/CFT – simple as that!”
Recognition that AML is part of a bigger picture was also revealed: “I believe in the social responsibility of the role”; “My own moral code”; “It’s the right thing to do: just as I would intervene if I saw a burglary in progress, I do the same when I see a client with no source of wealth explanation and unusual transactions”; “I protect the financial services system”. Two respondents were particularly outraged (and I mean that in a complimentary sense – I’m all for outrage when it comes to money laundering): “I like to know who I work with/who the customer is – I don’t like being fooled, taken advantage of. And I don’t like anyone whose main purpose is to f**k others, especially poor desperate people – that goes for some commercial legitimate business too.” And “Because of the human cost of money laundering and terrorist financing. I want to fight against children being abused, families ripped apart and for freedom of belief. I look through all we have to do to try and understand what I could be potentially stopping at the coal face. I find it much easier to get colleagues on board when I make them think about what regulation is working to prevent, and that is criminals exploiting other human beings whether they be white collar criminals or people traffickers.”
From my perspective as a trainer, it helps me enormously to know what influences, encourages and alienates you when it comes to AML, so that I can pitch my approach correctly – and indeed look for examples of where our efforts have been effective against the things that upset you. I can only hope that any regulators, legislators or investigators who may be reading will think the same. And from a personal standpoint, I am delighted to know that I have found my people – I salute you all.
This piece first appeared on Susan’s blog, I hate money laundering.