ICT Views

The AML/Compliance framework for Dads

by: (Associate Director, Research and Development) on

Being a Dad – there’s no handbook, regulatory or otherwise, but lots of people want to share their ‘best practice’ with you.

Hmm – sharing best practice you say. And Fathers’ Day coming up. Maybe there COULD be some comparisons between the more standard ICA/ICT content and father’s day. So here goes:

KYC (Know Your Child) / CDD (Child Due Diligence)

This might sound obvious, but the best way to manage the risk in your relationship is to apply robust KYC. In your father/child relationship, you must assume the role of the Relationship Manager.

Father's DayYou don’t need to check/revalidate their ID every 12 months, but every child is different. One might like carrots, one might like sweetcorn. Both might like football, neither might like cricket. To get the most out of your relationship, take the time to find out what it is they like/dislike. Like a HNW customer, it doesn’t mean they have to get their own way all the time, but robust KYC/CDD will let you know when something isn’t quite right in terms of the expected nature of the relationship.

And that means you can recognise any ‘red flags’ that may arise. Do they seem to have gone quiet? Don’t like a club maybe? Perhaps they have fallen out with a friend and you need to investigate further. Remember – not every red flag automatically means something is wrong – but recognising the unusual can help.

Risk Ratings

By successfully undertaking KYC/CDD you will probably establish that some children can be classed as low risk (you know you can let them get on with it – they are pretty much self-sufficient, but will let you know if they have a problem). They might need checking on every so often, but they come in and do their homework, wash their hands before dinner, and so on.

Others have a cheeky glint in their eye. They like a bit of mischief. They’ll eat that cake as soon as your back is turned, and then swear blind they didn’t (whilst smiling). These might be classified as ‘high risk’. Their CDD needs reviewing much more often, to check that your information on their activity is up to date and relevant. They might even ask you to bend the rules – buy them that ice cream, but not tell Mum….

Rules, Principles & Outcomes

On the subject of rules - as well as the Relationship Manager, you are also the lead regulator. Like an international firm, children will also have other regulatory influences. The school, for example, are one. Grandparents maybe too (albeit they are not renowned for handing out much enforcement action). Increasingly, like a firm, they are also influenced by the media.

So how do you handle this? Do you go for rules, principles or outcomes?

Let’s try one in practice.

The required action: Brush your teeth then go to bed.

The rule: You must be in bed by 8pm, having cleaned your teeth.

The principle: The best time to be in bed is 8pm, and clean teeth are a way to ensure good oral hygiene.

The outcome: Fresh breath and a good nights’ sleep.

The main thing from my point of view is the outcome. I’m down with the principle, but the rule might not work. Some kids thrive on rules and structure, some don’t respond well at all and want to do the opposite. And to be fair, the approach may also change with age.

I think that what I’m getting at is that effective regulatory oversight of bedtime and teeth brushing may require a variety of regulatory styles being implemented to be successfully achieved. And the regulatory model itself might have to evolve. Sometimes a single regulator (Mum or dad), but sometimes Twin Peaks regulation (Mum + Dad).

Personal Liability and Remediation

The fact of the matter is that you won’t always get it right.

Despite your best efforts in assessing risk appetites and applying oversight and controls, knees will get scraped, drinks will get split and lunch will end up all down their t shirts.

You’ll feel bad sometimes, but most of the time you’ll feel great. You’ve got a job where you can have a real impact and make a genuine difference.

It might not be the most well paid, and it’ll probably tire you out, but it’s the best job in the world and surely one of the most rewarding.

So happy Fathers’ Day to all the other dads out there.

There’s no policies or procedures except the ones you build yourself, so make the most of it. And remember not to take your work home with you (that IS best practice).


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Ruchi Trehan said...
Fabulous analogy in particular the red flag and bend the rules one! Even though KYC and CDD are no rocket science, many do not get it right always and this article will help most to relate to amd hence more successful application.
June 18, 2015 07:43
Anthony Beckett said...
Spot on thanks Dave. As with most RM's the policy that kids always seem to forget is 'What part of thou shall not do you not understand'!
June 17, 2015 09:37


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