The 4th Money Laundering Directive came into play in June 2015 with a timeline of two years for full implementation and carrying severe penalties for any financial companies who are not compliant. Yet, despite this, we’re rapidly approaching the halfway mark for this implementation and it appears an alarming number of companies haven’t even concocted a plan of action. With all of the other many regulations that have been brought in on similar timescales (such as MiFID II), it seems that the 4th Money Laundering Directive is the one that has been lost in the shuffle.
It’s alarming - particularly when you reflect on some of the incredibly harsh penalties levied against organisations that have fallen afoul of previous anti-money laundering directives. The most memorable recent case of this surely has to be the HSBC being linked to money-laundering activity by a Mexican drugs cartel, resulting in the global banking leader being fined £2bn in penalties.
If that’s not enough to motivate you to mark June 2017 in your diary with permanent red market pen, we don’t know what is.
Yet the FSA and European Parliament have gone one step further and are now making senior compliance officers personally responsible for mis-steps in this process. Accountability is in full-force here, as individuals who can be proven to have been negligent can face personal fines and even time in jail.
This personal accountability is a refreshing change for the market and something that will hopefully make clients feel more comfortable paying contract rates for compliance specialists. Whilst many customers feel engaging interim staff is a costly but necessary exercise in situations like this, there’s always the fear that you’re paying increased rates for something where the ultimate result won’t be known until long after the contractor has moved on. As much as our trust is usually rewarded with capable, reliable work, there’s always that fear that you could outlay a large sum of money to somebody who could make a mess everything - and then walk away scott free. No more. This stance of personal accountability means companies can guarantee good results from their senior workers (unless their hires inexplicably want to take a break at Her Majesty’s leisure?!)
So, with that in mind, there’s never been a better time to hire compliance contractors - although the competition is going to be intense. Not only are all companies affected by this directive but they all seem to be behind schedule. Make no mistake about it, there is going to be a rush on hiring and it’s going to be in the next six months. Further competition will come from the permanent market where some companies have decided to offer salaries almost at the consultant level with benefits on top in order to engage staff for the long term.
Our advice here is simple - act and act now. Plan properly, understand what you need to achieve by when, and who you will need on board to achieve this. With the clock ticking, now is not the time to start thinking about planning. It’s time to start doing.