Seriously, if you have been given this information by someone who sells his expertise as a consultant, an information provider or training / education provider, find someone who knows what they are talking about.
If you’ve heard it from a fellow money laundering compliance / risk management officer, think again about their risk assessment capability. Doing your job is tough enough without other people’s failure to understand their subject area sabotaging your own efforts.
When you are selecting your own advisers, think carefully: big law firms and consultancy practices advised HSBC, Standard Chartered, Lloyds and other European Banks on their risks in US businesses. Several of those advisers specifically told their clients I was wrong when I explained how the US Sanctions system operated , and how the USA PATRIOT Act would operate against foreign transactions. I told them that before the USA PATRIOT Act was in force. If you know your stuff, it is plain from the text of the Act.
I explained how transfer pricing and the use of royalties and intellectual property would become useful for both laundering and tax evasion almost 20 years before governments finally noticed. I pointed out the risks in trade financing and explained trade -based laundering before it even had a name.
There are far too many people who simply repeat what they hear, who have a far too shallow understanding of the issues, who focus on the simple movement of money and fail to recognise that it’s people who launder and more attention must be paid to those people.
There are far too many people who are selling “expertise” that has remarkably little value to you.
There are far too many companies and even governments that happily buy low level, repetitive, recitations of law and regulation, and the pre-scripted risks that so many regulators provide and do not look beyond that.
There are far too many people who focus on the acquisition of letters after their name, for which their companies often pay, rather than on the acquisition of true knowledge and understanding.
The control of money laundering and terrorist financing is for the protection of society, as well as other ends. It is a civic duty, regardless of law, to help detect and deter the commission of a crime that undermines society.
This is why Compliance / Risk Officers must identify the best sources of information, consulting and training and must insist, in the face of objections from Human Resources which has a different agenda, on using the best.
If you are not learning new stuff, if you are not being challenged, if you are not scratching your head and saying “I don’t get it, but I will work at it until I do,” then you are short changing yourselves and your company and – most importantly – society.
Don’t listen to false prophets or the mundane. Find someone who really knows what he is talking about and book him, even though it’s more expensive. Look for someone who knows his stuff and don’t assume that a qualification from a commercial entity is a guide to that.
Most of the very experienced people in this field do not belong to any of the commercial companies that issue certificates. That, of itself, should tell you something.
© 2015 Nigel Morris-Cotterill
All rights reserved.
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