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January 15, 2013


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Rowan Bosworth-Davies

An interesting comment, but once again, redolent with special pleading. Yes, it is true that the regulations dealing with money laundering controls have changed intermittently in the past, and different jurisdictions have slightly different issues to contend with which need regular monitoring, but the basic, fundamentals of AML compliance have not changed since the laws were first enacted. Banks have certain priorities to perform with regard to AML compliance and first among those is the requirement to disclose bona fide suspicious transactions. Of course there are KYC issues to apply, there are sanctions issues to oversee, and there are transaction monitoring requirements to maintain, but, at the bottom, is the requirement to disclose the suspicions of criminal activities, including those of the bank itself, LOL! Nothing has changed with regard to that basic premise, and I and my colleagues in NCIS and the Metropolitan Police spent many months working with the banking industry, spelling out in words of one syllable, what needed to be done to maintain and perform a best practice regime. The role of MLRO is a difficult one, but it is not as hard as this gentlemen seeks to maintain, and with proper systems, structures and controls, coupled with some common sense, and a great deal of moral integrity and courage to stand up to the finance people, and tell them to their face 'You can not do that', the job is a workable one. Unhappily, I know too many MLROs who will say 'Yes, but I would never get the backing of the Board to do that', and that is the problem.


Rowan, good comment and I look forward to following this debate.For anyone who has been glued to the evidence coming out of the Banking Standards Commission over the last few weeks a lot of scared cows are being unearthed at long last.There seems to be a role for a whistle-blowing system.I would be interested to hear your views on how effective this could be.As Michael Cohrs said yesterday in the first public discussion from the Financial Stability Board- let there be more open conversations shining light on the issues.

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