This week, talk show host David Letterman will be calling it quits after 33 years on the air. As the sardonic voice of a generation who believed that you can challenge authority, call out the phoniness of entertainers and politicians, and be self-effacing, Letterman changed the dynamics of public communication. At times cranky, but always creative, David Letterman will leave a void in these times of excessive political correctness and narcissism.
How does this apply to AML, you may ask (and my editor is contemplating right now)?
There are two answers.
First, we shouldn’t believe everything we hear—not from regulators, bankers, law enforcers, the media, nor even bloggers. Calling out any of these groups for selective outrage or inaccuracies with humor or facts (or both) should be embraced.
Simply smiling and bowing during a speech, address, or press release should never occur. We should analyze, question, and, when appropriate, push back.
Silence can indicate support in so many ways. Letterman always let you know how he felt about a guest or issue.
Secondly, many of us came to enjoy Dave’s “Top Ten” lists as a great peek into the current themes of the day. Many of you have attended the ABA/ABA Money Laundering Enforcement Conference over the years. You’ll recall how my friend and colleague Rick Small took the concept of a top ten list and adjusted it for the AML community.
As one of Small’s “ghost writers” (I can tell you that the ones that were left on the cutting room floor were the best—but many couldn’t handle the truth), and with tongue jammed firmly in cheek on some of this, I will take that concept and give you my:
Top Ten Reasons AML Is Without Comparison
10. What other profession can be used to address drug and human trafficking, elder abuse, and terrorism?
A key element of our community action is to both provide law enforcement with essential financial data and for the government to utilize the skills of private sector analysts.
9. When you tell family and friends what you do, so many make lame jokes about washing machines and dirty laundry.
It could be worse. You could tell someone you are with a bank and they ask about their credit card charges.
8. You can watch Al Pacino’s “Scarface” and tell anyone who will listen, “Yeah, those wheelbarrows full of cash actually happened.”
7. Virtual currency providers actually care what you think.
They may be loath to admit it. But without a clear understanding of how to address any potential vulnerability to financial crime, virtual currency will not last. This industry needs AML professionals.
6. Where else can you get the ongoing commitment of true law enforcement public servants such as IRS, FBI, and Homeland Security Investigations?
All three are true private-public partners who walk the walk and talk the talk.
5. What other profession gives you so many acronyms to spice up your chatter with? Such terms as CDD, EDD, KYC, CIP, CTRs, SARs, STRs, FATF, RBA, OFAC and many more?
Well, probably the medical profession, but still …
4. You can assess a risk to your institution and still have regulators second-guess your decision.
Oh wait, that’s actually not a good thing. It should be on a top ten list of things that need to be changed.
3. You can giggle about stripping wires and using pivot tables and no one will understand what you are talking about.
2. People who are uninterested in your profession suddenly change when you discuss banking marijuana dispensaries.
And the #1 reason that AML is without comparison:
1. While business lines within financial institutions work to increase revenue, AML professionals and their government counterparts actually make a difference in our lives!
Even if you were not a fan of David Letterman, there is no denying the need to be open and candid about our community—we are all committed to the same goal but sometimes need a little humorous prodding.
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