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Blog 2010

My current blog is on the Susan's blog page - this is an archive of my thoughts from 2010.

Thursday 30 December
Holidays do race by, don't they?  That said, I am happy to be back at work - lots of lovely ML stories to follow up (how dare they convict Khodorkovsky while I was in Slovenia?).  We went on a group tour (never again...) and over the course of the ten days, four people confessed to tax evasion.  Of course, they didn't realise that that was what they were doing, and they didn't realise my interest in the matter, and they were actually rather proud of their actions, but it did show me just how sticky a crime this is.  Like the tree falling in the wood, is tax evasion still a crime if no-one condemns it?  (Please don't write in: I think we know the answer to this one!)

Saturday 18 December
I'm listing to starboard.  My life is run by lists - my husband jokes that he can get almost anything done as long as he puts it on a list and forges my writing so that I think I've planned it.  And what with trying to clear the decks before a holiday, I've gone overboard on the lists (and the nautical metaphors).  Today I found myself pinning one of the fridge that says simply: "Check all lists!!!!".  I really do need that holiday!

Thursday 16 December
I've been having a dither this week.  I was considering whether or not to write some template policies and procedures for the Bribery Act 2010 (which bites in three months' time) - it is a business opportunity, certainly, but is it for me?  And then a friend solved the dilemma for me.  "Do you get angry about bribery?"  he asked.  "You know: the way you get angry about money laundering - at dinner parties...".  And he was right: my blood doesn't boil about bribery, any more than it does about fraud or people trafficking or drug smuggling.  They are all terrible crimes, and we could do without them, but what incenses me most is people profiting from them - I think that's the root cause of (nearly) all crime.  If we can stamp out laundering, we'll stamp out most crime - so that's where I will continue to focus.  Dither sorted.

Monday 13 December
Working alone, without an IT department, I have learnt a few tricks over the years.  "Turn it off and on again" is always a good response to any technical problem.  And to that I would now add: "leave it alone and go and have an elevenses break".  Yesterday I kept hitting metaphorical brick walls online - couldn't download my online statements, couldn't pay for things, couldn't set up direct debits.  I don't know whether it was Wikileaks-protest-related or not, but leaving it to stew in its own juices for a couple of hours seemed to do the trick.  Much better than getting in a sweaty and sweary flap about it all.

Thursday 9 December
I'm feeling much more positive today - probably because I spent yesterday training real people.  Sometimes, when I've been cooped up too long in the office doing preparation and research, I forget the real reason I got into this line of work: sharing my enthusiasm and concern (obsession, some might - and do - say) for money laundering with as many people as you will allow me to see.  My main task between now and the new year is to plan the next in my series of workshops for experienced MLROs - that always makes me feel rejuvenated and excited.

Monday 6 December
Some days I feel like I am chasing my tail.  I have been at the computer since 8am today - apart from a brief interlude to inhale a few Jaffa Cakes - and have yet to start any proper work.  I've been filing, tidying, answering queries, opening post - five hours and nothing that I can point at and say, "I did that today".  Funny how some days feel so productive, and others it's barely worth leaving the sanctuary of the duvet.

Tuesday 30 November
I must say that I feel sorry for all of you who are having to turf out into the snow today - I have the heating and a fan heater on in the office, and only a steady intake of chocolate digestives is keeping me from falling into a cold-induced stupor.  And commuting is particularly hazardous: yesterday I slipped in the garden en route to the office above the garage, and today am sporting a fetching array of bruises.  The problem with working for myself is that there is no-one to sue for this work-related injury and distress - no win, no fee, no chance.

Friday 26 November
I had what my gran used to call an awkward beggar in a seminar yesterday - he didn't bother me personally (you meet these people from time to time) but he did suck up valuable time and he created an uncomfortable atmosphere for others who were embarrassed by his behaviour.  When I was a teacher, I used to send such people out of the room to cool off - I wonder if I'm still allowed to do it?  I couldn't send him to the headmaster, but perhaps to the director of his professional body - a tempting thought!

Wednesday 24 November
Doing this job makes one extremely suspicious.  Yesterday I went on a day trip to France, driving through the tunnel.  Pulling into the train behind me, at about an inch a minute in order not to bash their wing mirrors, were two young men in a left-hand-drive Bentley with English plates.  I'm still mulling it over.  A rich French chap who pays them to bring the car "home" for servicing?  A VAT scam of some sort (French drive, English plates)?  Or something more sinister...?

Friday 19 November
I am relishing working from my office today.  Sometimes I forget how lucky I am, but this week I have experienced the London tube at its busiest (apologies again to the chap whose foot I balanced on for four stops) and Ryanair (need I say more?).  So I am particularly thankful that most of the time I can work without having to battle to my desk - and of course even Ryanair is likely to object if I turn up in my jammies and dressing gown.

Wednesday 17 November
I was working at a client's office yesterday when we had an unexpected fire drill.  Sadly no firemen in evidence, but we did have to walk down six storeys and gather outside while the building was searched and declared empty.  I felt particularly sorry for the people turfed out of the gym in the basement - one poor chap was swaddled in about six towels, trying to preserve his dignity.  But what excitement: I don't experience this sort of thing, working on my own in a room above the garage.  Perhaps I should appoint myself a fire marshal and have regular drills and evacuation practices.

Thursday 11 November
Today, as you know, is Armistice Day.  Having lost five great-uncles (all of my grandma's brothers) in the war, I am very keen on commemorating this day.  When I am alone in my office, observing the two minutes' silence is simple.  And if I'm training, I explain why it matters to me, and I stop for the silence.  But it's much harder when you're on the move, or in a meeting.  I suppose I should be like my grandma: she used to say that she didn't need a specific occasion to remember her brothers, and moreover that silence was an odd way to do it as they were the noisiest bunch of lads she had ever known.  So here's to you, my boisterous Great-Uncles Jackson whom I never met: thank you.

Monday 8 November
I know I've said this before, but being an organised person can be a dreadful curse.  I've just had a client make a training booking for April - that's April 2012!  I realise that the compliance sector attracts those who like detail and planning, and perhaps I am just their dealer, feeding their craving for organisation.  Serco (the wall planner people) don't even print their 2012 planners until March 2011 (yes, I've checked), so we're well ahead of the game here.

Thursday 4 November
Just call me Valerie Singleton!  I turned up at a client's office today to do some training for them, and we didn't have a screen for the projection.  So I dashed to the nearest charity shop, bought a white duvet cover for three pounds, and sellotaped it up to serve as a screen.  For my next trick: AML training via charades.

Friday 29 October
Do I really need to reiterate that I am obsessed with money laundering and financial crime?  I see it everywhere - every news story has (for me at least, even if for no-one else) a money laundering angle.  So I was delighted to turn on Radio 4 this morning, and hear Thought for the Day on the "Today" programme, as it was all about the Corruption Perceptions Index!  It is certainly in my thoughts for the day - and hopefully now in those of lots of other radio listeners.

Tuesday 26 October
I think I may have a problem: I woke up this morning, and my first thought was not "What shall I have for breakfast?" or "I wonder if the cat has brought in another dead mouse?", but "Hurrah - the Corruption Perceptions Index 2010 is out today!".  I am a huge fan of Transparency International and the sterling work they do to highlight the effects of corruption at all levels, and their CPI always makes such interesting reading.  Of course, it means that all my planned presentations for the next few weeks have to be revisited, but it's worth it to have the very latest info.

Saturday 23 October
I know, I know - I shouldn't be working on a Saturday.  But my usual Friday afternoon reading slot fell by the wayside as I tried to get some work to a client before the end of the week, and so I'm doing the reading now.  At least it keeps me out of the shops, if not away from the biscuit barrel.  (An interesting concept, that: I suppose it dates back to ship's biscuits being kept in barrels, to keep out the weevils.  Mind you, it would have to be a speedy weevil to beat me to the chocolate digestives.  Or perhaps, to pay homage to Tommy Cooper, the lesser of two weevils.)

Wednesday 20 October
For years I have used Comic Sans as the font for my emails, judging it to be legible, friendly and not Times New Roman.  And then I find that it is the most hated font in the world (http://www.bbc.co.uk/news/magazine-11582548), considered "irritatingly simple", best used for "parish newsletters" or to convey "faux joviality".  Oh dear.  I've changed back to Arial for the time being, until I can decide on something more inspiring.

Monday 18 October
I was explaining to a new friend over the weekend how I ended up in this line of work (long story short: I read an article about money laundering and thought it was the most fascinating subject ever) and realised how serendipitous it all was.  What if I had never read that article?  I wonder what I would be doing now...  Thank goodness for whatever steered that article my way.

Thursday 14 October
Do you think there's something wrong with me?  I've woken up early today, too excited to sleep, because I am holding one of my very favourite MLRO workshops.  I find these days so challenging and exciting - spending time with my favourite people (MLROs, of course) and debating important issues (money laundering, of course).  And regular food breaks, including gingerbread men in the afternoon - what could be better?

Wednesday 13 October
You never stop learning in this job.  Yesterday, for the first time ever, I realised that there was no way I was going to have time to cover everything I had planned to do in a training session, so I had to edit on the hoof.  Thank goodness it didn't happen when I was a new trainer - that sort of thing can put you off for life.  But it's good to know that such a thing can happen without the sun falling from the sky - although I did have a peculiar nightmare about it last night!

Friday 8 October
Goodness, where did that week go?  I suppose it's because I'm in the middle of my busiest season - Guernsey next week, then a fortnight at home including prep for an MLRO workshop in London, then another week in Guernsey.  I think people like to have training in the autumn because it reminds them of the new school year - new exercise books, sharp pencils and a resolution to do really well this year.  By spring, you're jaded and tired, and realise that you've spent more time in detention than in class - although hopefully not real detention for real compliance staff!

Monday 4 October
My first task every morning is to update my website and Facebook page, if there's anything appropriate.  Some might say that it's a depressing way to start the day, reading about rascals and rapscallions making off with looted assets, but it serves to remind me why I am doing this job, and why it matters so much that we get as many people as possible angry about criminals getting away with their profits.  So my first task every day serves to stiffen my resolve - onwards and upwards in the fight against laundering!

Wednesday 29 September
Over the past fortnight, I have been using my WhiteWash™ money laundering simulation with various groups of delegates, the majority of whom are accountants.  And it is always fascinating to see how someone's day job affects how they approach this exercise.  Police officers always consider the difficulties of investigation, while the accountants focussed primarily on the numbers - how to get the best risk reduction for the least money.  And when they write down their schemes, they put brackets around the numbers to be subtracted - very clear and precise.

Friday 24 September
I was doing some training for a client this week, and during one of the sessions - the one attended by the senior partner, the MLRO and the Deputy MLRO - I was asked all sorts of tricky questions.  The person who had commissioned the training apologised afterwards for the "hijack", but in truth I actually enjoyed the cut and thrust of digging into the legal niceties of the areas under discussion.  Whether the rest of the delegates enjoyed it, I can't be sure - but it certainly kept me on my toes and taught me something new.

Tuesday 21 September
As some of you will know, I like to award chocolate coins as prizes for various competitions that I run during training sessions - although it remains to be seen whether currency rendered in cocoa-based confectionary is mentioned specifically in guidance to the Bribery Act 2010.  I am running a couple of big sessions over the next few weeks, so I went into my local Thornton's to stock up.  And you should have seen the dinner-plate eyes on the little boy watching me stagger to the till with arms full of bags of chocolate coins - if I had wanted to adopt him, he would have come with me then and there.

Thursday 16 September
Home safe and sound - no thanks to budget airline travel.  Say no more.  If you can turn up the volume in private, this is just fantastic as an expression of the frustration we all feel from time to time when offered "cheap flights":  http://www.youtube.com/watch?v=ZAg0lUYHHFc  It's not for those offended by bad language...

Monday 13 September
I've presented in some unusual venues in my time, but today was my first cinema.  I'm working in Gibraltar, and the new cinema complex has gone into the corporate events business.  It's a very comfy room, and the seats are tiered, so everyone gets a good view - but I couldn't shake the feeling that I should have come up through the floor while playing a piano!

Friday 10 September
I've developed a bad habit.  Whenever I hear something new and relevant, I add it to whichever presentations I am working on at the time.  This week I have been attending a conference and listening to all manner of speakers, and gathering all sorts of new information.  So I pity the poor people I am training in the next few weeks, as their presentations are growing by the minute.  Do you think more than a hundred slides in a morning is too many...only kidding!

Wednesday 8 September
This week I am popping in and out of an economic crime conference here in Cambridge, and yesterday I had a most invigorating day.  I spent time with three nice chaps from the SFO, debating the finer points of PoCA, and then another group discussed "whither the risk-base approach" before I finished off the day thinking about failures in corporate governance and why CEOs of large firms are rarely (never?) former MLROs.  It's good to meet some fellow obsessives - it's like a large meeting of Compliance Addicts Anonymous (except that we all wear name badges).

Monday 6 September
I have a friend who works for an advertising agency, and she gets some marvellous perks - product samples, glamorous parties, etc.  In my line of work, perks are rare - actually, extinct (and maybe it's just as well, given the Bribery Act 2010).  But thankfully my husband works in another industry (cycling), and I can sometimes get "perk by association".  So in a fortnight's time, I will be whizzing around the highways and byways of East Anglia, following a stage of the Tour of Britain in a team car - very exciting.  Of course the professional cyclists today are young enough to be my sons, and the ones I fancied rotten have all retired with arthritis, but a late perk is better than no perk at all.

Thursday 2 September
I've been reading a book about "crime signals" - how to spot criminals from their body language and other things.  And, just as reading a medical dictionary brings out the latent hypochondriac in us all, I am now seeing potential criminals everywhere.  If someone blinks too much, I don't think that they have grit in their eye - I think that their body is preparing for action and clearing their retinas for sharp focus.  If I see someone sweating, I don't think that it's a warm day - I assume that they are struggling with the stress of lying.  Perhaps I should read something more soothing for a while.

Tuesday 31 August
I always see the second August bank holiday as the end of summer, so now I'm embarking on my busiest season.  It's been a crummy summer weather-wise, but I've done lots of interesting reading and research, and am full of new ideas for training, workshops and writing.  But first - a chocolate biscuit.

Friday 27 August
As yet another example of my fanatical appetite for planning, I set aside Friday afternoon each week to catch up on my reading.  I found some time ago that if I just leave things in a pile (or indeed an e-pile) and hope to get around to them, it never happens.  But Friday afternoons are quiet - clients are winding down and rarely contact me with queries or concerns - and it's a gentle lead-in to the weekend.  So waiting for me this afternoon are a report on employee fraud, a book about criminal behaviour, an academic dissertation on the effectiveness (or otherwise) of PoCA, and the latest issue of Marie Claire.  I'm a woman of catholic tastes.

Wednesday 25 August
I've just realised that I forgot to tell you how my first training session went last week.  Well, I enjoyed it tremendously - I always miss training over the summer.  And I managed to get through three hours of talking without losing my voice, although I did get cramp in my foot at one point and had to hop around while discussing the intricacies of the training defence - perhaps that should be part of the FSA's fit and proper test for MLROs.  After all, hopping shows fitness while training shows properness.

Thursday 19 August
It's the first day of school for me: my first training session since the end of June.  I'm very pleased to get back to it, but slightly nervous too.  What if I've forgotten it all?  What if I can't remember the names of the legislation or the launderers?  What if my voice gives out, or I fall off my heels after a couple of months in flatties?  But then I get to talk about money laundering for three hours - what could be better?  I love my job!

Monday 16 August
I forgot to mention the mini-collapse I had last week.  I was emailing a client, talking about some upcoming training, and I said that I would be doing my preparation for him in early September.  "Early September?" he said. "But the training's on 19 August."  "19 August?" I gasped.  "It's in my diary for 19 October!"  Quite how the snafu happened we're not sure, but it certainly lit a fire under us.  All is now in hand, and the delegates themselves will be unaware of the swan-like mad paddling beneath the surface, but my client and I both aged rather quickly.

Friday 13 August
Almost everyone I email pings back an out-of-office message about being on holiday until 16 August - I'm feeling very left out (or left behind).  I know I've had my holiday, but when you're working hard at your desk, you like to think of everyone else similarly anchored - not drinking Technicolor cocktails on a beach somewhere.  I tried putting an umbrella in my mid-morning glass of iced tea, but it just wasn't the same - maybe because I was reading a dissection of the Bribery Act, which takes the celebration out of the occasion.  I hope those holiday-makers are all paying for their own drinks...

Wednesday 11 August
I like to add at least one news story to my website - or my new Facebook page - every day.  But that requires there to be a suitable news story (i.e. real money laundering, not alleged or potential, or perhaps some juicy new legislation) and it's been very quiet lately.  I know that the media talk of summer as the "silly season", but how can that be the case all over the world?  It's not summer everywhere, and surely criminals don't take long breaks.  I'll keep looking.

Monday 9 August
In the words of Jack Nicholson, I'm ba-ack.  A friendly neighbour kindly corralled the post every day, otherwise I wouldn't have been able to open my front door, so most of yesterday was spent opening envelopes - a bit like the Oscars, only with fewer tears.  And today I'm tackling the email.  We had a lovely holiday, and I managed to become quite proficient in explaining to strangers all about "blanchiment d'argent" - as well as sitting on the back of a tandem with my feet on the handlebars.  I don't think he noticed, which is rather galling.

Friday 9 July
Well, this is it: my last working day before a month off.  You should see the to do lists - they're truly epic.  A couple of weeks ago I went through the hell of changing my web hosting package, mainly so that I can have an "out of office" message when I am, well, out of office.  Here's hoping it was worthwhile!  You will be glad to hear that my luggage is stuffed with back issues of "Money Laundering Bulletin" and "Fighting Fraud", as well as a stack of crime-themed books - and my trusty little notebook for jotting down ideas on how I can do more to help MLROs.  You are always on my mind, as they say.  I wish you all a lovely summer, and will be blogging and Facebooking again from 9 August.

Monday 5 July
I've been reading a book called "The Business Playground: Where Creativity and Commerce Collide".  Using their (literally) thought-provoking exercises I've had a few barking ideas, swiftly discarded, but I have decided to give this Facebook lark a go.  I have a personal page, so that I can keep up with young rels who can't write, take normal photos or send postcards but can always update their "wall", but now I've decided to see whether having a business page is worthwhile.  After all, the MLROs out there are getting younger every day...  So, it's in its infancy, but why not ?  I'll do my best to keep up.  Just don't expect me to start Twittering any time soon.

Friday 2 July
Yesterday evening I went to an MLRO networking event for the local branch of the Law Society.  I can't say much, as it was very kind of them to let me attend given my non-solicitor status, but let's just say that it was illuminating and shocking in equal measure.  Plenty of work still to be done, I think.

Wednesday 30 June
I very rarely envy people who work in big offices - after all, they can't go to work in their nightie, or take a break to watch a restorative episode of "Frasier" - but for the past few days, I've been dreaming of working in a big, cool, air-conditioned building.  Imagine the swish of the door, feel the cold blast of the aircon - aaaaah!  Meanwhile, the cat and I are melting in my home office above the garage, eating industrial quantities of ice-cream (me, not the cat) and lying on the desk with all four limbs akimbo (the cat, not me).

Monday 28 June
Regular readers will know that I am a great planner.  However, even I am having slight conniptions at what I am doing today, which is deciding dates for my island visits and therefore my holidays for 2011.  It's not as simple as you think: I have to consider school holidays (not for me, but because I know that client staff will work around them), my local book club (which meets on the second Monday of the month, and I hate to miss it - in fact, if anyone does miss a meeting, the accepted excuse is that they are in Guernsey!) and my other half's travel plans (so that the cat doesn't starve).  And the thought that, by the end of today, I will know what I will be doing in December 2011 is frankly a bit scary.

Thursday 24 June
As predicted, there was a complete meltdown today: first of my website, then of my email, and finally of me.  So apologies if you tried to look at the website and found a blank space, or sent me an email and have not had a reply (please resend).  I was given lots of technical "assistance" by the web-hosting people, along the lines of, well, it's your ftp protocol rejecting the DNS settings, I should think.  I eventually found the solution in the form of a large slice of tirami-su: not for me, but as a bribe to get my husband to sort it all out.  Ta-da!  And now I need a quiet lie-down.

Wednesday 23 June
I'm a little nervous, because tomorrow I am changing my website hosting package.  No, I don't know quite what that means either - except that this blog and everything else on this website could disappear into the ether.  The techie person advising me assures me that "uploading the htmls" and "resetting the DNS" will be the work of moments, but I am girding my loins for the challenge (which, in my case, means buying in large quantities of Jaffa Cakes).  Here's hoping we're still here at the end of the week.

Monday 21 June
I am a regular reader of the Spectator, and was horrified to read in a recent issue a "Diary" by Conrad Black, convicted fraudster and jailbird.  I emailed the editor to check whether Mr Black had received any payment for the piece.  I have just received confirmation that "Conrad Black doesn’t ask for payment, and doesn’t receive it", which mollifies me slightly - although the self-pitying tone common to those of his ilk, and the assertion that "I have met [in prison] some undoubtedly dodgy characters, but none whose ethics struck me as inferior to some of the prosecutors and judges I have encountered" served to remind me why he is sitting in a little cell in Coleman.  For a man currently embroiled in an appeal, he'd better hope that the judge doesn't read the Spectator.

Friday 11 June
I had a realistic and very scary dream last night: I dreamt that I had gone grey with one of those Cruella De Vil white streaks, and that I arrived a week late for my "How to be an MLRO" workshop only to be told that the workshop had been taken instead by the black and white cat that hangs around on the balconies outside St James.  I've diagnosed over-work and have started to self-medicate with Jaffa Cakes.

Tuesday 8 June
Is anyone else addicted to "Mary, Queen of Shops"?  How can I get her job?  It's so much easier to go into other people's businesses and see the problems and the solutions - much easier than doing it for your own business.  Perhaps businesses should get into groups and do that ghastly thing that happens at some dinner parties, where half of you move around between courses, so that you meet new people.  We could all move along a desk or office, and look at someone else's work for a while.  For a start, the MLRO should swap with the Head of Sales.

Tuesday 1 June
I went to a wedding in Germany at the weekend, and was stranded at the airport when easyJet cancelled all of its flights.  We were basically left to sort it all out ourselves (we came back on another airline to another airport) and I wondered about the level of service.  What would happen to my business if, just as delegates were settling in their seats and fighting over the best biscuits, I turned to the MLRO and said, "You know, I don't fancy training today - it's cancelled.  You can find another trainer yourself - there's always the Internet."  That's a direct quote from the easyJet staff, by the way: "There's always the Internet."  Thank goodness it was only a day's holiday I missed, rather than a day of booked work.

Wednesday 26 May
One of the most frustrating aspects of my work is the travel.  Not actually being in different jurisdictions, but getting to them.  No sooner do I get used to a flight timetable that the airline concerned has a tinker and it's all up the spout.  For instance, there used to be a lovely evening flight from Gibraltar to Stansted, which meant that I could do a day's work and then set off home.  No more: now the only flight offered by Monarch is at noon.  Noon!  Can't work before, can't work afterwards - a complete waste of a day.  Harrumph!

Monday 24 May
I am reading just the most fascinating book at the moment.  It is about money laundering (what else?) but was published in 1975, so it really is a work of history.  It's something of a primer for Americans wanting to use the Swiss banking system (as it was in the 1970s, I stress again) and it really makes your hair (and toes) curl.  Even the quantities of money involved are interesting, e.g. "Imagine you owe the IRS a staggering $10,000..."  Staggering?  Really?  The danger is that it all sounds so quaint and almost lovable that it's easy to forget that here are the roots of our current problems cleaning up a global financial system that is shot through with criminal money.

Thursday 20 May
If, like me, you find large numbers hard to visualise and compare, this (heard this morning on Radio 4) may help.  How long is a million seconds?  11½ days.  How long is a billion seconds?  32 years.  Mind-boggling.  That's going to fascinate me all day, and I'll be telling everyone - you have been warned.

Tuesday 18 May
I'm having a clumsy day - do you have those?  Everything I touch I manage to drop, break or lose.  So far I have had to apply two plasters and several layers of arnica cream, and I've stubbed my toe - and it's only 10am.  So I apologise in advance if I've made terrible clangers on the website today - it would be entirely in keeping with my general cack-handedness.  I'm planning to stick to non-essential filing and admin duties, rather than anything that might matter.

Friday 14 May
Wheee!  I'm still on a high after yesterday's "MLRO IV" workshop in Jersey.  I just love doing workshops - they keep me on my toes and give me the opportunity to get to know more lovely MLROs - and this one was a cracker.  Exhausting but fantastic.

Wednesday 12 May
I'm in Jersey for the week, and it's a home from home, as the streets are thronged with gangs of French children here to learn English - just as they are in Cambridge.  But as the little darlings spend 90% of their time in and around McDonald's, I should imagine that the only English they learn is "A Big Mac and fries".

Sunday 9 May
Long-standing clients will know of my, well, fondness for Sean Connery - based entirely on his James Bond persona, rather than any dodgy submarine captains, SNP campaigners, etc.  So imagine my shock on reading this headline: "Sean Connery linked to Spanish money laundering probe".  Shurely not, as the great man himself would say.  But it turns out that he plays only a bit part in this intrigue: the great man bought a villa in Marbella in the early 1970s and sold it in 1998, when it was knocked down and replaced with flats, which locals now say should not have been granted planning permission.  So nothing to do with my, sorry, our James, sorry, Sean.  Phew.

Wednesday 5 May
The FSA has fined another firm and MLRO for AML failings (see Stop Press page).  Most of the failings were to do with due diligence and monitoring (or the lack thereof), but the final notice also commented on the level of AML training within the firm: "Alpari gave informal, one-off, one-to-one training when employees joined and updated staff on an ad-hoc basis.  This was inadequate as demonstrated by the failings identified in the files reviewed by the FSA."  I realise that in times of hardship, the training budget is the first to go, and I quite see that an external trainer might be an expense too far.  But as this comment shows, every MLRO must be able to demonstrate that their staff are still given a regular programme of relevant, adequate, appropriate training - even if he's rolling up his sleeves to do it himself.  "Informal" and "ad-hoc" seem not to cut the mustard with the FSA.

Tuesday 4 May
I went out to dinner on Saturday night, and during the meal the conversation turned to Kennedy.  I mentioned that old Joe had been a bootlegger and used the money to fund political campaigns for his sons, and that JFK had had mob connections and that his friendship with Frank Sinatra had been built on their shared interest in curvaceous ladies and slightly shady men...  When I paused for breath, I realised that everyone was staring at me, forks poised in mid-air.  "We meant Nigel Kennedy - the violinist," someone explained.  Obsessed?  Moi?  Note to self: stop ordering large pallets of financial crime books from Amazon.

Thursday 29 April
And I thought it was just me.  I've recently started wearing reading glasses occasionally, when my eyes are tired or when the print is particularly small.  After a recent workshop, one delegate commented that she couldn't read some of the small bullet points on the printouts, so from now on I will print two slides to a page rather than three.  My very first client retired at the beginning of this year, so I suppose I shouldn't be surprised that my other clients are aging right along with me!  Perhaps I should think about MLRO magnifying glasses as prizes...

Monday 26 April
Back on dry land - Cambridge is sixty miles from the sea, which is about right for me.  On my first-ever visit to Guernsey, the old compliance dog I went with warned me, "Whatever you do, don't confuse them with the other islands - they hate that".  It's stuck in my mind, and I live in dread of saying Jersey when I'm in Guernsey, or Isle of Man when I'm in Cayman.  This year, in three consecutive months, I am running whole day workshops in all three Crown Dependencies, so the chances of my slipping up are high - perhaps I could just refer to the Isle of Jernsey.  Apologies in advance if I offend anyone - but as I spend my life explaining that Oxfordancambridge is not a single university, I know how you feel.

Tuesday 20 April
Now I know how Scott must have felt when he struggled all the way to the Antarctic only to find that the blasted Norwegians had got there first.  I did a ten-hour, cross-country, multi-transport journey to the Isle of Man today - bicycle, then train, then walking, then train, then taxi, then ferry.  And as I was walking from the ferry terminal to the hotel, I looked up - and a plane went overhead.  Harrumph.

Sunday 18 April
It must be payback for my complaints on Thursday: it now seems unlikely that I will be able to fly to the Isle of Man on Tuesday as planned.  So I have booked a back-up ferry crossing just in case.  And what is the mode of transport I fear most?  Yep, boats.  I blame it on over-exposure to "The Onedin Line" at a tender age - all those high seas and people falling off the topsail.  I'm hoping the ferry requires a bit less input from its passengers.

Thursday 15 April
I'm not a happy flier at the best of times - it's tolerable because it gives me an excuse to read a trashy magazine and eat a Twix, but that's about it.  The Polish plane crashing into the trees, well, we all knew that could happen - flying too low in fog, bad idea.  But clouds of volcanic ash getting into the engines and stalling them?  News to me.  So now I'll have to check for potential eruptions in the vicinity of all my island destinations - is Burhou by any chance a dormant volcano?

Tuesday 13 April
I love running workshops, I really do.  There's only one part of the process that I loathe, and that's assembling the delegate folders.  I don't mean writing the materials - that's great fun - I mean actually punching holes in it all and stuffing it into ring-binders.  For a start, my desk is too small so I have to do it on the floor, which makes my knees ache.  And then - once I've put thousands of pieces of paper into what feels like hundreds of folders - I find that I've used the wrong size binders and put everything in upside down.  That'll teach me to sing along to the radio rather than paying attention.  And finally I nearly fell off my bike taking the huge box of folders to the post office - those of you with reprographics and post room staff who do all of this for you, you don't know how lucky you are.

Sunday 11 April
There's nothing like a deadline to stir the legislators into action: the Bribery Act 2010 received Royal Assent three minutes before Parliament was prorogued at the end of Thursday 8 April.  Its date of commencement has yet to be announced.

Friday 9 April
I've just taken delivery of my diary for 2011, and have already started putting in various bookings.  It's wonderful to have such loyal clients but i do wonder, as my grandma used to warn, that I'll get so far ahead that I'll meet myself coming back.

Wednesday 7 April
I have a confession to make: I am a wicked and lazy trainer.  When the election was called yesterday, and it turns out that they have only until the end of tomorrow to pass all the pending bills through parliament, I crossed my fingers and said, "Please oh please oh please let the Bribery Bill not make it".  I don't have anything against the bill per se - in fact, I think it's a fine piece of legislation - but if it is passed, I'll have to make changes to about ten presentations that I am giving in the next few weeks.  See: just pure lazy.

Thursday 1 April
I suppose I should create an April Fool's trick somewhere on my website but the truth is that criminals are so inventive that anything I could make up would sound credible.  So I shall content myself with having spotted the "Today" programme trick on Radio 4 this morning: apparently some evidence has emerged that William Shakespeare's mother was French (they say that her surname was not Arden, but Ardenne...) and so the French are claiming that Will is a French playwright rather than an English one.  It's not like football, you know - you can't uncover an Italian granny and claim to be Tuscan to your toes.

Tuesday 30 March
People sometimes ask me why I go to Guernsey so often - at least six times a year.  Well, it's a virtuous circle: because I go so often, I am well-known there, and because I am well-known, I am booked again, and so I go more often.  Plus it's a lovely place to visit - that walk into town through Candie Gardens is hard to beat.  I'd like to go to other islands too, but I'm still struggling to build my reputation in those places.  For example, my "MLRO IV" workshop in the Isle of Man is going well, but it's taken me four months to sell twelve out of sixteen places.  When I recently announced the same workshop in Guernsey, I sold all sixteen places within a fortnight.  Apparently, it's not what you know, but who you know and - more crucially - who knows you.

Thursday 25 March
Yesterday I did some training for a company in London, which has 75 employees.  On the train to Liverpool Street, I noticed a man sitting across the aisle from me, mainly because he was tearing pages out of his diary and scrunching them up - I always keep my diaries for seven years for the taxman.  Anyway, when I arrived at the company, there he was.  So the man sitting near me, whom I had specifically noticed, out of the million people who use that station every day, was one of the 75 employees.  Spooky!

Friday 19 March
Most people would agree that I am quite a sociable individual.  I certainly love meeting people who come to my training.  But I am hopeless when it comes to small-talk at conferences.  I went to one yesterday, and it was really hard to go up to strangers (who often attend with groups of colleagues and so have their ready-made groups during breaks, peer at their chests to read their name-tags, and then do all the "So, what do you do?" stuff.  I know conferences are always touted as "ideal networking opportunities", but I very rarely find them to be so.  Women's magazines often have tips for mingling at parties - learn a good joke, wear a statement piece of jewellery, offer to hand round drinks - but I don't think any of that would go down too well at a professional conference.  Except perhaps the tray of drinks.

Tuesday 16 March
I may have been a little over-ambitious.  I am now organising four workshops in three jurisdictions between now and October.  I am a contender for the world's most organised person, with a collection of coloured folders and sticky labels that would be the envy of anyone, but as it's just me, with no-one to double-check my admin, my fear is that I will book someone on the wrong workshop.  Or - worse - that I will go to the wrong jurisdiction on the wrong day.  I'm sure Ban Ki-moon has similar worries.

Friday 11 March
As Guernsey readers will know, small but significant changes are being made to their proceeds of crime legislation - altering the wording of some offences, changing the test of suspicion on one, and so on.  As I was describing these changes during training yesterday, I said, "So it's very exciting times here in Guernsey."  The delegates laughed as though I had made a joke - but I realised that, as far as I was concerned, it really was exciting.  I tell you, this money laundering obsession is an illness.

Wednesday 10 March
I'm working in Guernsey this week, and the airline managed to lose my suitcase on the way out - yes, between Stansted and Guernsey.  It turned up a day later, but in the meantime people were so kind: a complete stranger in the hotel bar lent me his laptop power supply, and the hotel receptionist found me a warm jacket in the lost property box.  What I missed most was the special box of chocs that I always take with me to cushion the effect of being away from home for a week - rose and violent creams, as my German friend once called them.  Thankfully, chocs and I are now reunited.

Thursday 4 March
People often ask how I can stay interested in one subject for years (I think they mean money laundering rather than chocolate, although I have stayed loyal to both).  The truth is that I have been incredibly lucky in stumbling (and I have to admit to that - pure luck) on a topic that is so varied and so fat-moving.  This week alone we have had new guidance in the Isle of Man and the promise of updated legislation in Guernsey, as well as an imminent report on the effectiveness of the AML regime in the UK.  Even with just six main jurisdictions to track, it keeps me more on my toes than Margot Fonteyn in her heyday.

Tuesday 2 March
It's obviously only a trick of my mind, but it seems that when I am really busy and cannot stop for anything, the emails come whizzing in at the speed of light - every time I do a send and receive to send something, another ten come in.  But when I am actually waiting to hear from someone, it seems that the whole system has slowed to a crawl, and I begin to check my computer's connections to the network, my networks connections to the outside world, and how long it is until elevenses.

Friday 26 February
It's an illness, I tell you.  I'm talking about my inability to resist buying any book or film or magazine with the slightest connection to money laundering.  At the moment I am reading am autobiography called "Do Time, Get Time", about the misadventures of a crooked Russian banker.  I thought it would tell me all about his laundering methods, but in fact it starts on the day of his arrest, and concentrates entirely on his prison experiences.  I'm hoping he will eventually have a trial and all will be revealed, but apparently even getting a trial in Russia is an uphill struggle - mostly they toss you into jail with all sorts of nasty people who do unspeakable things to each other while calling each other "Comrade".  Barbara Cartland, it ain't.

Tuesday 23 February
I am going demented.  As a one-person business, I am very proud to be able to do almost everything associated with running a business: the actual work, the stocking of the stationery cupboard, the office cleaning.  I even do my own bookkeeping, which I find oddly therapeutic.  But not today.  My books don't balance, by some piddling yet infuriating amount.  I've gone round and round, but can't find the problem.  It doesn't affect much at all, but I'm not going to let silly numbers beat me - I will find the error!  Perhaps a few Jaffa Cakes would help the little grey cells.  Worth a try.

Friday 19 February
Those of you who have ever tried to reach me by mobile phone will know what a frustrating experience it is.  I very rarely switch it on, and when I do, I tend to leave it in a coat pocket or my other handbag (the choice is wide).  I did consider getting a Blackberry (mainly because I like the dinky little leather cases you can get for them), but I fear the story would be the same.  After all, I grew up in an era when - if you wanted to get in touch with a friend at university - you didn't Tweet them or text them or email them or put something on their Facebook wall: you wrote a note on the wipe-clean kitchen notice-board stuck to their room door.  Try leaving that in your other handbag.

Wednesday 17 February
I "attended" a "webinar" yesterday.  (I'm not at all sure about the word "webinar": is the stress on the first syllable, or does it rhyme with Ribena?)  As a face-to-face trainer, I am naturally sceptical about any other sort of training, but I can see that this solution is a useful one: I sat at my desk, while the speakers were in, well, I don't know where they were, and they spoke and showed their slides and I listened.  At first I wondered whether they could hear me so I kept very quiet, but of course they couldn't.  And then I picked up a book that was lying on my desk (about a big cash robbery) and flicked through it, and before I knew it, I'd read two chapters and missed half a webinar.  Ah, that's the problem - no actual human engagement.

Wednesday 10 February
I know it's a cliché for women to worry about what to wear, but today I do have a dilemma.  I'm off to London in a little while, and I'm visiting a potential new client, so I need to look professional.  But to get to London, I have to cycle to the station, and it's snowing and perishing here today.  So I need to find an outfit that is smart, warm, waterproof and cycle-friendly (i.e. with a wide skirt) - and on top of it I have to put my day-glo waistcoat to make sure that no driver claims not to have seen me when I ride home in the dark.  Gentlemen, you have it easy.

Monday 8 February
I went to Paris at the weekend (caught the tail-end of the sales - bad news for the old credit card) and coincidentally walked past many of the grand addresses and premises that are familiar through the work of Global Witness.  This is a fab organisation that investigates and publicises instances of high-level corruption, and many of these naughty people spend their stolen money on living the high life in Paris (who wouldn't)?  So I walked along the road where Denis Christel Sassou-Nguesso and his mum had their lavish apartments (funded by Congolese oil money) and past the expensive men's outfitters that he used.  I saw the bank (which shall remain nameless) that to this day holds accounts for Omar Bongo of Gabon - even though Tracfin wants them closed.  And I spent a happy half-hour in the best chocolate shop in the world.  Oh, that's nothing to do with corruption: that's for me.

Tuesday 2 February
I cleaned my office the other day - as a one-person business, I have all the jobs, including office cleaner - and went through my desktop set of drawers that serve as my in-tray, out-tray and pending.  And in the pending drawer, I found a bag of Maltesers.  I can't remember putting them there, which makes their discovery even more pleasurable, but if I did: what was I thinking?  Pending what?  Ah yes, pending my cleaning the office and deserving a treat.  I knew there was some justification.

Friday 29 January
I'm devising a new "revision game" for my training - these are the little quizzes I run at the end of training to revise the material we have covered - and so have spent a lot of time on websites designed for primary school teachers.  I've had to dismiss some of the suggestions as just too juvenile, but you'd be surprised how many of the principles of teaching apply right across the board, from tiddlers learning to count to staff in the regulated sector learning to recognise suspicion.  Here's hoping I don't need to instigate a naughty step.

Wednesday 27 January
Do you ever feel that your life is passing too quickly?  Today a client asked about my availability in autumn 2011 - yes, that's 2011!  They've already booked for November 2010, and want to be able to demonstrate annual updates.  One of the best things about working with compliance people is that they are great at planning and detail, and one of the worst things about working with compliance people is that they are great at planning and detail.  Heavens, I'm a forward-planner, but even Filofax won't start selling its 2011 diaries until March this year.  It's a bit sad that I know that...

Monday 25 January
Sorry for the silence: I was away in Guernsey last week, and I'm never comfortable about updating my website files via a public wifi network - someone might hack in and say all sorts of nasty things on my website.  (It's happened before...)  It was interesting to see Guernsey in a state of high alert pending their AML/CFT evaluation visit from the IMF in March and May.  The regulator is issuing handfuls of "Instructions" with very tight deadlines, regulated firms are being visited and given only minutes to respond to recommendations - it's a frenzy of activity.  I expect every Guernsey MLRO to take a well-deserved holiday in June.

Wednesday 13 January
I'm hoping to run a workshop for MLROs in Jersey in May, but - thanks, I think, to stiff local competition - it has been remarkably hard to get people to sign up.  I was on the verge of cancelling but decided to make one last plea to just about everyone I know in Jersey, and they ahve come up trumps for me.  I can't tell you what a relief it is when people actually want to come to a workshop that I am offering - I live in dread of finding that people have lost interest in the whole thing.  (Not me, of course: I'm as obsessed as ever.)

Monday 11 January
I must find a way to switch off more effectively.  The first hour of every Monday is spent gathering up the work-related notes I have made over the weekend and left dotted around the house - wedged into my handbag, stuck on the fridge with the Paddington magnet, tucked into my Filofax - and then taking them into the office to decipher.  What do you make of one that says "Call M re October"?  It made sense at the time.  I suspect my husband - who is a great advocate of the "leave work at work" mantra - is leaving me dummy notes just to watch me squirm.

Wednesday 6 January
I am exhausted.  Yesterday I just couldn't get started with an article I had to write, so I decided to do my archiving instead.  This is nothing exciting, such as one might do at the British Museum, but simply clearing out my old paper files.  (I still have plenty of these, despite all those techies promising us "the paperless office".)  Although it was therapeutic to throw away lots of old documents (I particularly enjoyed shredding all reminders of a very awkward ex-customer), I've now ended up with dozens of piles of paper on the floor, looking for an archive cupboard.  The cat is doing her best to rearrange them for me.  And I have an uneasy sneaking suspicion that the local paper bank has just swallowed something that I haven't looked at for years but will need with great urgency tomorrow...

Monday 4 January 2010
So here we are, back at work after the loooooong festive break.  I'm amazed by how empty my email inbox is: it seems that even spammers have family to visit at this time of year.  That said, we are always warned that Christmas is a bumper time for money launderers, who hope that the financial sector will be less vigilant than usual, so let's hope that none of "my" MLROs comes back to a nasty surprise today.

 

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