ACAMS Today Magazine (March-May 2011) Vol. 10 No. 2 | Page 11

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