Remember to mitigate the threat
- Corruption, Fraud and Money-Laundering, are real threats which cost companies billions every day. Achieving compliance towards regulations, industry-standards and investor-policies, are not the goal - mitigating the threat is the true goal. Compliance is only a neat bonus, although a demanding one.
Don’t begin by hiring a provider
- Begin with your internal capability, hire an external person who is responsible directly to you and your company. Let this department get an overview of the situation. This ensures that your providers can’t sell you crap software (A.I.) or persuade you to hire an army of external consultants - to do ridiculously highpaid low-key work.
Don’t be confident
- The developing possibilities for conducting fraud, money-laundering and corruption is proportional with those in any other busines. Technology and new approaches are constantly being developed, and few are capable of keeping up. Be humble, and expect that your knowledge was outdated yesterday.
Don’t give a large budget
- Even though the issue may be huge, avoid giving a large or unlimited budget. This is an investment, and should pay off. Expect results from the beginning. They need to find cases of fraud, money-laundering and corruption to prove they're worth. But listen when they do. Then, they may increase spending. Otherwise, these first steps will eat the internal goodwill, moreover there won’t be a budget for the expenses that may come later. Remember, you could find some very disturbing issues that will need financing to be solved.
Don’t hide the department far away
-The head of you Anti-Money Laundry or Anti-Corruption has to pull rank towards other departments. Since they won’t help anybody with less work (but more), and they might reveal huge internal lacks - they need to be able to hold their ground to perform. Otherwise they will be pushed away once things get serious.
Expect the worst, and say it publicly
- Why? You will find cases of Fraud and Corruption, and need to prepare every one for it. This approach makes you the source of news on the subject, and it makes it credible when you later state that all is fine. Moreover, you avoid a long row of negative news. You already said that something was coming, and you were right. You may state later, that due to your great efforts, the issues was mitigated and all was fine. This makes bad news, good news.
Keep it high and close
- Put your new department next door so that you can see what they are doing, and to ensure that they are developing in the right direction. You don’t want middle managers who are eager to tell you everything is fine, to later discover that the capability never was there. Yes, you should send the department overseas once it’s up and running, but that may take time.
Avoid big brands
- Anti Money Laundering is big business - and so is Anti-Corruption . The big brands are aware of it, they are campaigning and are investing big time in winning assignments. However, software-, accounting- and legal-firms are not experts on this subject. They are also learning how this is done, but they do know how to sell them self. And prefer customers to pay for their learning curve. Its not illegal to fake it till you make it!
Don’t be leading in the field
- This is obvious. Let your competitors make the mistakes of implementing A.I. without any effect, or hiring 100 James Bond agents for a billion pounds a month. Learn from their mistakes, and wait for effective proven solutions. Behind any IT scandal is a IT-company that fooled a customer - You get the point.
Don’t go for name-dropping, fancy abbreviations and professional slang
- Any abbreviation or expression has a meaning. Ask for what the meaning is, in common English - and ask again. If you don’t, employers and providers will try to fool you. Yes, sorry they have!
Don’t expect that this is under control
- Unless your team can prove it. If they never or rarely found any cases, or you never heard of any - they are certainly shit at what they do. Because everybody is targeted constantly. You either know it or you don’t!
Would you like to know more?
Contact us via email or phone