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.
Money laundering and I – or rather, AML and I – have been on intimate terms for more than two decades now. The muscle memory in my fingers is such that I cannot type the word “money” without following it with “laundering”, and almost any word beginning with a capital M ends up as “MLRO”. I feel rather protective of AML, even maternal towards it. We’ve been through a lot together. We weathered the storm in 2005 when the Third European Money Laundering Directive allowed that upstart, that impostor, that johnny-come-lately terrorist financing to have equal billing, so that all of a sudden everyone wanted to talk about some hybrid creature called AML/CFT (and sometimes AML/CTF – even uglier).
But recently things have Gone Too Far. As I have said in earlier posts, the new AML legislation in the UK has the most ghastly name: the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 – so that’s someone else muscling in on AML territory. And in Guernsey they are now talking of renaming the MLRO as the FCRO – Financial Crime Reporting Officer. The cuckoo in the AML nest.
I am often asked whether I can deliver training on “financial crime, including money laundering, corruption, tax evasion, cybercrime and so on”. To me, this makes little sense. Money laundering is not a financial crime: it is the financial crime. All of the others are simply crimes that generate money – with some of them doing it by abusing financial institutions. Once the basic crime is committed – whether it’s drug trafficking or bribery or cyber-fraud or art theft or tax evasion – the criminals proceeds are then available for the main event: money laundering.
Money laundering is not like other crimes: it is not done to make money, but rather to preserve and disguise money from other activities. (Granted, there are a few professional money launderers who make their living from money laundering, and when we consider how to prosecute them – for laundering the proceeds of laundering – it’s something of a legal minefield.)
So please: let’s restore money laundering to its rightful place as the financial crime supreme, the one that touches every other acquisitive crime. Demoting it to the status of a standalone crime, just something else that can be done to make money, downplays its importance, its spread and its danger. AML for one, and one for AML!
This piece first appeared on Susan’s blog, I hate money laundering.