Regrets, I’ve had a few – well, OK, one

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As I bring down the curtain on my AML life, I am reflecting in this penultimate post on what I have achieved, the direction my career has taken, and any opportunities missed.  To be honest – and this might come as a surprise to those who know me, and my ever-present Filofax, and my “dish of the day” list pinned onto the fridge every Sunday evening for the coming week – I didn’t have a career plan.  My main skill has always been communication – written and oral – and I stumbled across the subject of money laundering while engaged on another technical writing project.  And reader, it was love at first sight.  Once I knew what money laundering was, and how desperately so many people wanted help in explaining AML to their staff and clients, I was hooked.

Inexplicably, I have never grown bored with the subject – perhaps because it changes so frequently, with new laundering techniques, new legislation, new AML guidance and products and ideas.  And I have been honoured to have so many repeat clients – after all, the most honest positive feedback is another booking.  But there is one thing I did want to do that has eluded me.  It’s a confession of my vanity, but I longed to be part of a strategy-setting group.  I thought that with my experience of helping MLROs on a daily basis, I would provide an unusual – and essential – perspective when discussing, for instance, new AML guidance, or changes to legislation.  I would be the one saying, “Well, that’s an excellent idea, but could we use the word ‘must’ instead of ‘should’, so that the MLRO can demand, rather than request, an increased budget from the Board?”.  Or “That’s all very well in theory, but what is the Guernsey/Jersey MLRO meant to do to find PEPs who have been removed from all the UK/US-created commercial databases after twelve months, but are still PEPs under the local legislation?”.

I did try, oh, how I tried.  I responded to every consultation going, with detailed comments and hints at how I would be able to give oh-so-much-more detail in person.  I volunteered for every round table and discussion group and talking shop and breakout session.  I offered to review and edit documents for free.  I contacted every AML-ish gathering I could think of – such as JMLIT and all its predecessors in the UK – offering my time.  The only organisation ever to take me up was RUSI.  All the others said that, far from being an advantage, my “unique perspective” was the problem: I didn’t fit into any of the categories that they had decided to include.  I wasn’t a regulated entity, I wasn’t a trade body, I wasn’t a lawyer or a banker or a civil servant, and so no chair at the table would be right for me.  On reflection, I suspect I simply came across as an enthusiastic amateur.

But in all honesty, if I can look back at a career lasting a quarter of a century and have only one significant regret, isn’t that amazing?  And I know from the lovely emails and notes I have been receiving that my primary focus – “my” MLROs – have found my enthusiasm and championing of their cause to have been worthwhile.  I have loved it all.