EXPERT SPOTLIGHT
ACAMS Today: Describe your current position
and responsibilities?
Simon Dilloway: I have my own business
which includes several companies. My main
work at the moment is AML training and
giving advice to the international public
sector law enforcement. Also, I have just
come back from training visits to Russia and
Ukraine, and I am in the middle of rewriting
the Vietnamese Handbook for ML investigators and prosecutors. In addition, I provide
AML reviews and solutions to UK regulated
companies, and have a third interest in an
online e-learning and name checking site that
is under development.
AT: How did you first become involved in law
enforcement and the compliance field?
SD: I joined the Metropolitan Police in
London in 1976, and served for almost 31
years. The latter part of that service was as
a detective financial investigator, dealing
with anti-corruption, drug trafficking, money
laundering and ultimately, terrorism at the
National Terrorist Financial Investigation
Unit (NTFIU), then part of Special Branch at
New Scotland Yard. After retirement in 2007,
I started the companies mentioned above,
and launched into my new career in the
compliance field.
AT: What is the key to having a successful work
relationship between law enforcement and
compliance professionals?
SD: This is something that I was very much
involved in while at the NTFIU. The key relationship has to be one of mutual trust — this
is the most important thing. Clearly, those
involved in compliance have legal obligations, both in disclosure and confidentiality,
and on the other hand, law enforcement has
to be careful not to reveal sensitive or classified information. If, however, both sides can
go the extra mile to make the job easier for
each other, we will at least be one-step closer
to beating the bad guys.
AT: During your career you have been a part
of many AML, TF and financial crime investiga
tions, what commonalities have you found?
SD: An interesting question! Paradoxically,
one of the common things is how different
each investigation is. By that I mean that
every time you investigate money laundering
or terrorism, you find some new twist that
be looking for transactions to or from countries known to be destinations, or transit
points for TF. They should thoroughly check
identity of clients, and be especially vigilant
for any reluctance to provide supporting
evidence of identity.
Criminals are always
developing new methods
in the face of ongoing
legislative improvements
In truth, however, there is no foolproof
method beyond what is done for AML. The
important thing is ensuring that procedures
are as tight as possible, and that record
keeping and archiving are accurate and efficient, so that when law-enforcement comes
calling, firms are able to supply top quality
information quickly. That was the best help I
could get as an investigator.
you have not seen before, because criminals
are always developing new methods in the
face of ongoing legislative improvements.
This is why I always preach the risk-based
approach so passionately. It is the only way to
avoid getting bogged down in set typologies,
which itself leads to missing new methods of
moving or disguising dirty money.
AT: How can those commonalities best be
exploited by the compliance professional?
SD: The commonalities that are there need to
be shared. This is an area where competition
must be set aside, and the experiences of one
institution should be broadcast to everyone
else. This is of course promoted by many
industry organizations — especially ACAMS.
Ideally, firms should be