Fool’s gold in Catalonia

The ink may be dry on the Third EU Directive but there is still plenty to play for in the comitology discussions and at national level as Timon Molloy reports in his second instalment from Money Laundering Alert’s Second Annual European Money Laundering Conference in Barcelona.

There is always a danger of reading too much into what may be only passing remarks, but a couple of comments by UK speakers on the “Third EU Directive” panel at the Money Laundering Alert’s Spain conference at least hinted at a subtle change of emphasis in UK AML philosophy. EdnaYoung, Sector Manager, Financial Crime at the UK Financial Services Authority alluded to an “output-focused” approach: “Do the systems employed deter criminals?” she asked. John Mair, Group Financial Crime Director, Lloyds TSB, also speculated that outputs are “more important perhaps than inputs”. He added,“We need sufficiently informal arrangements, as well as formal, to be effective.” Mair was supportive of the risk-based approach, a leitmotif of the Third Directive text, as long as it proved flexible: “The assessment of risk needs to change with the [actual] risk otherwise we’re in danger of finding that all our defences are pointing in one direction,” he said.