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Emerald Group Publishing Limited
Copyright © 2011, Emerald Group Publishing Limited
Article Type: Editorial From: Journal of Money Laundering Control, Volume 15, Issue 1
A few moments on the web might well convince the casual inquirer that there is a new job creation scheme afoot – involving training in fighting financial crime. The provision of training for those involved – in broad terms, in compliance – was much slower to develop in Britain and certainly the rest of Europe, than the USA. Indeed, some early and even university-backed programmes collapsed because of lack of support and interest. However, over the last 20 or so years a veritable new industry has developed and blossomed – to some extent officially sanctioned and mandated, providing various levels (albeit not degrees!) of training on for example anti-money laundering procedures and systems. This has recently been extended, in part as a result of Section 7 of the Bribery Act 2010, to the area of anti-corruption. Of course, there is great variety both in the form and content of training. The only common denominators are that it is expensive and partial. Of course, training does have an important, indeed, vital role to play in ensuring that there is sufficient awareness of risks and that there is at least an acceptable, albeit basic and response. Equally axiomatic is the observation that the vast majority of training does not contribute in any tangible form to value other than comfort!
Various bodies such as the International Compliance Association (ICA) and the Chartered Institute of Securities and Investments (CISI) have attempted to create a series of “professional” qualifications in certain compliance-related areas. Indeed, some have been recognised, by universities – such as the University of Manchester, as having a significant academic content, or at least justifying credit in related academic programmes. While the orientation of these initiatives is almost inevitably commercial rather than professional, the quality of the training and in particular the documentation is generally good. Indeed, there is now a significant market for British-based programmes overseas and some foreign governments particularly in South East Asia and the Middle East have sponsored their local development. It is interesting that new areas have been identified – such as compliance in Islamic financial institutions and although the quality of these products is not uniform they are at least timely.
The ICA rolled out a full-developed programme in financial crime prevention several years ago which is now offered in a number of countries and is generally highly regarded. Others have now jumped on the bandwagon. Even the City of London Police is keen to market its training potential. Perhaps, the most significant competitor to the ICA is likely to be the CISI, which launches its new training product in financial crime-related compliance at the end of October 2011. The problem with such programmes is that they tend to fall between two stalls. They are often prepared by academics (in the case of the CISI’s an American) who no matter how eminent may or may not have had exposure to the practical issues and yet are addressed to a market which is almost wholly practitioner orientated. Of course, the notion that risk and risk management can be addressed, let alone effectively taught, in silos is itself – dangerous. For example, in practical terms a major area of concern within the city is the inter-play between rules, both domestically and internationally, and in particular the inter-relationship of civil, regulatory and criminal laws. Such issues are at best little more than alluded to in these programmes.
Training programmes are of obvious importance, however, while they stand alone without the support of more developed and articulated programmes in the business schools and universities, the knowledge imparted is at best one dimensional. The ball has been put squarely in the court of universities – particularly those in and around the City of London to take these somewhat basic initiatives and integrate this body of experience into programmes of the level and sophistication that the world’s prime financial centre deserves. Sadly, however, there appears to be little appetite for this – perhaps because training pays rather better than scholarship!