The Mary Poppins Approach to AML: A Spoonful of Engagement

This blog draws inspiration from a presentation at the AML and Financial Crime Conference, hosted by The Law Society, held on Thursday 26th of September 2024.

Mary Poppins' wisdom extends beyond childcare, and into to the world of Anti-Money Laundering (AML) training. Just as she found joy in mundane tasks, we can approach AML compliance with a positive mindset. By making the learning process engaging and interactive, we can ensure that team members not only absorb the necessary information but also enjoy the journey of becoming AML experts.

Effective training serves as a powerful and reliable indicator of compliance within an organisation. This relationship between training and compliance can often be observed through a clear cause-and-effect dynamic. When employees receive comprehensive and engaging AML training, they are better equipped to understand and implement compliance measures in their daily work. Consequently, this enhanced knowledge and awareness typically leads to improved compliance outcomes across the organization. The direct correlation between high-quality training programs and increased compliance levels underscores the critical importance of investing in robust AML education initiatives. Our shared goal should be to cultivate employees who are passionate about and committed to AML practices in our firms. For what reason do we strive to achieve this ambitious goal?

By fostering a team that is genuinely invested in AML compliance, we create a robust defence against financial crimes. Passionate employees are more likely to stay vigilant, spot potential red flags, and proactively contribute to the ongoing improvement of our AML processes. Moreover, their enthusiasm can be contagious, creating a culture of compliance that permeates throughout the organisation and ultimately strengthens our reputation in the industry.

Our role as gatekeepers is multifaceted and crucial in the fight against economic crime. We stand at the forefront, vigilantly monitoring clients and matters. We all have a responsibility to safeguard not only our firm but also the broader economic landscape and society from the corrosive effects of money laundering. This dual role demands unwavering commitment, expertise, and a proactive approach to identifying and mitigating risks.

AML training should be ongoing. Ask yourself, how do you deliver training in your firm? Is your current training programme effective? Have you stress-tested your AML training?  Remember, variety is the spice of life. Ask your audience what they'd like to see. How can you make your training engaging and relatable? Can you tailor it to your firm or specific departments to make it more relevant? How can we enhance our training methods and mindsets, challenging ourselves to push beyond our traditional approaches?

Ineffective training is often generic, irrelevant, and delivered as a one-time event. It fails to engage employees or address their specific needs. While we must cover mandatory elements to provide our staff with a basic standard of information, we must keep the conversation of AML compliance alive throughout the year. There are many effective methods we can deploy to do this, below is a brainstorm of ideas that you could consider implementing.

Engaging AML Training Ideas

• Interactive Case Studies: Present real-world scenarios and have employees work through them in groups, fostering discussion and practical application of AML principles.

• Role-Playing Exercises: Simulate potential money laundering situations, allowing employees to practice identifying red flags and following proper procedures.

• Storytelling Sessions: Invite guest speakers from law enforcement or compliance to share real-life money laundering cases and their impacts.

• MLRO Open Office Hour: A dedicated time when the Money Laundering Reporting Officer (MLRO) makes themselves available for all employees to ask questions, seek guidance, or discuss concerns related to AML. This approach provides an informal, accessible way for staff to engage with AML topics and receive expert advice.

• MLRO Spotlight: An opportunity for the MLRO to share real-life examples of red flags, themes, and redacted, anonymised insights from the firm's SAR reporting.

• Interactive Quizzes: Develop fun quizzes to test knowledge or just keep AML front of mind.

• Collaborative Mind Mapping: Use digital tools to create collaborative mind maps of AML processes, encouraging visual learning and team participation.

• Micro-Learning Modules: Break down complex AML topics into bite-sized, easily digestible content that can be accessed on-demand.

• AML Escape Room: Design a physical or virtual escape room where solving AML-related puzzles is key to "escaping".

• Resources: Share engaging podcasts on various AML topics for on-the-go learning. Share engaging on-topic webinars or insightful articles to supplement training.

• AML newsletter: Create a regular newsletter featuring recent AML developments, updated guidance, new legislation, disciplinary case studies, and money laundering news. This newsletter acts as an ongoing learning tool, keeping AML topics top-of-mind for employees between formal training sessions.

By implementing these engaging and relatable training ideas, we can transform AML compliance education from a mundane task into an interactive, memorable experience. This approach not only enhances knowledge retention but also fosters a culture of enthusiastic compliance within our organisation.

We should not approach training with a tick-box mentality, doing it merely because the SRA is watching or because regulations mandate it. Instead, we should train because it's necessary to do the right thing.