| 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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