What Lies Beneath

We are all prone to over-complicating things in our lives. Often in my role I have to remind myself to KISS (Keep It Simple Stupid!). With a plethora of legislation, regulation and guidance we can be forgiven for wondering what our next best steps should be when performing due diligence and fulfilling our anti-money laundering requirements. However if we boil things down to their absolute essence we simply need to be thinking about 'what lies beneath'.

Our forum is frequently filled with questions along the lines of 'what due diligence should I perform on X?'. If the guidance doesn't cover the issue we shouldn't be blind to the underlying message that runs through all of the legislation. We need to understand who, what and why structures are set up. When we talk about the rationale behind a structure we are simply trying to understand the purpose and the reason for any perceived complexity in any one arrangement. Who controls the structure? Who stands to gain from the set-up? Who has financial control? What is its purpose?

With the increase in regulation and regulatory burden if we can condense our obligations into concepts and principles for the business, training can be greatly simplified. We want to reduce box-ticking and enhance a thoughtful approach to the requirements. In the industry we often talk about the 'smell test', and often our senses will be urging us on as something may not 'sit right' with you. Follow your gut and your instincts and follow the leads.

Another issue that we often encounter is that clients may say 'we don't have enough information for effective searches'. This query frankly bewilders me - firms are in a great position when handed information such as date of birth, nationality, residency, business names, parent's names etc. All of these are additional identifiers, which should enable deeper and more effective web searches to dig out the necessary information to inform your choices. If the client is from a non-english company you must perform searches in their own language to ensure you are finding out all there is to know.

Remembering the basics and reducing things down to their simplest form always makes concepts easier to grasp. Simply bearing in mind 'what lies beneath' and the who, what, why, where and how questions should enable you to ensure that all staff are up to speed on their understanding of money laundering requirements. We are the gate-keepers and we should ensure that we really are doing all we can to protect ourselves and our businesses.

• Show All Hot Topics

Member Comments

Sign in or join the community and be the first to leave a comment!