Holmes: Four things to start a review of money laundering risk policies and proceedures.
I’d start with four conversations.
Not formal meetings, just four “windows” into how the firm really works.
1. The STR/SAR and escalation trail
Show me:
-Internal suspicious reports (even the ones that didn’t go to the FIU/regulator)
-How decisions were made
-How fast things moved
-Who was involved
You learn very quickly whether AML is a living process or an uncomfortable box-tick.
The interesting part isn’t how many STRs were filed, it’s how people thought about them.
2. The breaks, exceptions and “annoying things”
Not the glossy management information, the messy stuff:
-Reconciliation breaks
-Manual overrides
-Late trades, failed payments, margin calls
“Temporary” workarounds that became permanent
That’s where you see operational reality.
Controls look great on paper; the exception log shows you where they bend, creak or quietly get bypassed.
3. The Board / ExCo papers
I’m not looking for perfection. I’m looking for patterns:
-Are risk, compliance, AML and conduct discussed regularly?
-Do discussion / board information packs deal with themes and root causes, or only point-in-time
numbers?
-When something went wrong, was there a clear line: issue > cause >
decision > fix?
You can tell a lot about a firm by what its senior people choose to ignore.
4. Correspondence with the Regulator
Authorisations, routine queries, thematic reviews, findings, follow-ups.
---- Are responses timely, factual and calm?
---- Are agreed actions actually closed out?
---- Is the tone defensive, passive… or constructive and grown-up?
You don’t need a “perfect” relationship with your regulator.
You do need a credible story and no surprises.
The nice thing is: you don’t have to change jobs to do this.
You can ask yourself, right where you are now:
a) If I looked at our STR log, our exceptions, our Board packs and our
regulatory mail today…
b) Would I feel comfortable signing my name as CO/MLRO here?
If the answer is “not yet”, that’s not failure.
That’s your roadmap.
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