© Thinking about Crime Limited, 2022
registered in England and Wales as company number 4919193
SERVICES
Introduction
Thinking about Crime Limited offers a range of services to help you to prevent and
forestall money laundering, and therefore meet your legal and regulatory obligations
and protect your institution from infiltration by criminals.
The three main services are:
•
Training
•
Policy and procedure review and redrafting
•
Research
And whichever service you use, I will encourage you to stay in touch with Thinking
about Crime Limited, to contact me whenever you wish to discuss money laundering
issues that may be vexing you or training or policy issues that may be worrying you.
For more details about these services, please click on the buttons above left.
ANTI-MONEY LAUNDERING
TRAINING AND ADVICE
Training
I believe wholeheartedly that good training is the key to any institution's anti-money
laundering regime. You can have the best policies and procedures in the world, but
they will be worthless if your staff do not know about them, understand them and
know how and when to apply them.
And although good training is available, it seems that some regulated firms do not
realise how important it is to get the right training for their staff. A recent report from
the UK's Financial Services Authority (Banks' management of high money
laundering risk situations - June 2011) said this: "It is important for firms engaged in
activity with higher risk customers, including PEPs and correspondent banks, to
train relevant staff on the money laundering risks associated with them... We were
generally disappointed at the lack of bespoke training provided to staff directly
involved in dealing with high-risk customers."
Training - of all staff, from the most junior to the most senior and not forgetting the
compliance staff too - is a vital part of staff development and can ensure that:
•
your staff are able to recognise and react appropriately to suspected money
laundering - and therefore form an effective first line of defence for your
institution
•
your compliance officers are kept up-to-date with all the latest developments
in money laundering techniques - which helps them to be more effective in
their relationship with the legal authorities and more professional in the wider
performance of their role
•
your organisation will benefit from the "anti-fraud bonus" of being able to
recognise activities which are intended to defraud you
•
you will be able to satisfy both regulator and law enforcement, if you were to
inadvertently become involved in an investigation, that you had taken the law
seriously and were not turning a blind eye to its purpose and consequences.
Thinking About Crime Limited can provide a range of tailor-made courses, from a
simple one hour refresher training lecture to a full multi-day money laundering
training and awareness programme. Most clients opt for half-day or full-day
sessions.
Every single training session is individually designed for, and in collaboration with,
the client. Training can be designed to meet the requirements of any business
sector, in any jurisdiction in the world. Courses can be conducted in-house or at an
external location, and at times to suit the client.
In addition, I offer a range of other training services, such as standard feedback
forms, post-training support, and a post-training report which can form part of the
Money Laundering Reporting Officer's annual report (as required by UK legislation).
If you would like to know more about how I design training for clients, or to see a
"starter menu" of anti-money laundering training modules, please email Susan.
Policy and procedure review and redrafting
nternal anti-money laundering (and related) policies and procedures should be
regularly reviewed to ensure that they are both compliant and effective. A recent
report from the UK's Financial Services Authority (Banks' management of high
money laundering risk situations - June 2011) commented on how helpful it can be
to get regular reviews of your policies and procedures, as long as you then make
use of their recommendations: "It is essential for banks to update their AML policies
and procedures regularly to take account of new operational, legal and regulatory
developments and of emerging risks. Two banks in our sample had employed
consultants to review the firm’s policies, procedures, systems and controls... In
those cases, we found good AML policies that had either not been implemented or
were not understood by key members of staff."
Thinking about Crime Limited can look at your current policies and procedures, and
advise you on:
•
whether they meet the legal and regulatory standards which govern your
institution, and
•
whether they are effective - i.e. whether your staff can understand them and
know how and when to apply them.
This crucial service has the advantage of providing an objective assessment of your
policies and procedures (which may add weight to your efforts to make changes)
and also frees up in-house compliance time which would otherwise be spent on this
process.
If you would like to know more about the policy and procedure review and redrafting
service, please email Susan.
Research
There is an almost overwhelming wealth of information about money laundering,
financial crime and related compliance issues. Keeping up with developments
around the world is a full-time job – one of the jobs taken on by Thinking about
Crime Limited.
I conduct research on a daily basis and write regular columns for trade publications
and contribute to the national and international press and other media. I produce a
monthly e-newsletter for my clients. I blog feverishly. And I speak at conferences
around the world, alerting audiences to the dangers of money laundering.
If you would like to know more about these research, writing and speaking services,
please email Susan.