Consultants. Who needs them?
I was gutted. I'd just had a call with my boss who told me the company had engaged a consultancy company to perform a full review of the AML function. I’d been MLRO for less than a year, I was just about to start my ICA diploma and really thought I was doing a good job. Just to make things worse I was recovering from two leg fractures thanks to a surprisingly slippery bathroom floor! The last thing I needed was ‘these people’ sticking their noses in.
What was I doing wrong? Why hadn’t my boss or HR said anything before? If I wasn’t performing, why hadn’t I been pulled up on it? Oh god, I need to find another job, another career. I was devastated.
Up to that point I’d never worked with external consultants; my preconceptions were that they make money out of finding things wrong, and they were going to produce a report with fancy words telling the senior management that their MLRO didn’t know what he was doing.
I couldn’t have been more wrong. This was the best thing that had happened in my career (until I joined Betsmart of course).
I had to realise that this wasn’t about me, and once I understood that I soon recognised what a brilliant opportunity this was. This wasn’t simply an audit: it was my company being proactive and investing in compliance and their people. Large fines are of course a regular occurrence, and many public statements are stipulate that the offending company must arrange independent reviews as part of their settlements.
The company I worked for wasn’t in trouble with the Gambling Commission – and they didn’t want to be. They just wanted to make an investment to ensure it stayed that way.
I was nervous leading up to my first meeting with the consultants. I didn’t need to be. This wasn’t a test; they weren’t looking to see if I could recite regulation 19 word for word. They wanted to get to know me, understand my strengths and weaknesses, so they could identify how they could help me the most and really contribute to the company and to me.
What followed was the most amazing five-hour session, if it wasn’t for the cast and crutches from the afore mentioned leg break, I would have cartwheeled out of the meeting.
They could see I knew what I was doing but allowed myself to hide behind ‘business as usual’. I hadn’t made the adjustment which was needed when undertaking such a senior role. They identified I was lacking confidence when it came to making the big calls, such as ending business relationships with commercially valuable customers, and having to deliver the news to a director. In my head I had the preconceived idea that it would look bad if I had to do this, and that it would reflect negatively on me.
What the consultants did talk about a lot, was how they had found the company’s compliance culture, and that the directors they had spoken to as part of the review fully understood the MLRO’s role and that these decisions were not made lightly. This was a massive boost, and almost immediately I felt some of the self-imposed weight lift from my shoulders.
The review took a few months to complete, and yes there were some areas of improvement. But now I felt I had the confidence to execute solutions I may not have done before the experience.
The whole process gave me confidence in my own abilities, knowledge and decision making. They weren’t just consultants – they were mentors, coaches and ultimately great professionals, who many years on, are still personal friends.
From a business perspective the experience gave our leaders confidence that their compliance functions were working well. The consultant’s report provided assurance and directed important focus on areas which could be better, and which may benefit from further investment. The consultants also had the advantage of working with other companies which had been engaged in recent enforcement action and knew what short fallings were being commonly identified by the Commission. This was an invaluable ‘heads-up’ to what was happening outside our own four walls.
Many years on and now a consultant myself, I am a proud member of the Betsmart Consulting team. I love delivering the Prepsmart services we offer and seeing how they help compliance professionals and businesses across all sectors of the industry.
For me the saying of ‘fixing the roof while the sun is shining’ (John F Kennedy, 1962) rings truer and truer on a day-by-day basis (and let’s face it, the cost of maintaining your regulatory roof is always certain to be cheaper than most regulatory settlements and clean-up operations...)
Written by Nigel Harvey, Dip AML.