Most everyone would agree that the right tone from the top is crucial in enlisting the support and cooperation of the rank and file in any organization on any risk-related issue. This fundamental concept of internal control is particularly important in AML compliance, where lower-level personnel provide the first defense against money laundering activities. But here is an interesting question: What makes the tone form the top “right?” A just-released Protiviti white paper takes a look at the issue, analyzing the elements of effective messaging and concepts that stick, as well as the challenges presented by a diverse, multi-generational workforce.
The paper combines the views of our top AML consultants and training and communication specialists, for a well-rounded overview of what works, what doesn’t, and how to recognize important gaps in an organization’s AML communication so they can be fixed. It discusses key tactics and tools for effective communication: message relevance, respect for employees and their learning styles, multi-sensory learning, use of appropriate technology and understanding of the generation gap.
For example, something as simple as feeling valued and playing a meaningful part in a bigger battle with a personal element in it, such as human trafficking, can be much more effective in increasing cooperation among employees than receiving punishment for not following rules. Similarly, delivering a compliance message through technology already in the hands of the user, such as a smartphone, will work better than a bulky online course that takes away precious time from other duties of front-line employees. Applying these and other tactics to a customized communication plan tailored to the organization can spell the difference between an AML compliance program that works and one that fails.
AML compliance is equal parts art and science. We hope this paper sheds some light on the art of delivering effective AML messaging that is embraced and not ignored by the people working the front lines.