“We were taking over the payrolls for around 100 charities,” she says. “So suddenly we had to do AML checks for all those charities, and it was the payroll department that was tasked with doing it.”

“Payroll is probably one of those areas where it's easiest for things to go wrong with AML,” she acknowledges. “But it's also often a service that’s a bit separate from other work, which can mean payroll staff don’t always fully understand their part in AML compliance.”

“Having watched All Too Familiar, I decided it was ideal for these staff because one of the key issues played out in the film relates to payroll,” she says. “So the film’s release was perfect timing for us.” 

Stop and think

Caroline screened the film during a team-wide meeting of the payroll department. She explained its significance for them, not only in general terms but also because of their critical role in the onboarding of the new charities.

“Initially, I think the team was a bit unsure why it was being asked to watch this type of film,” she says. “But once everyone had watched it and we'd discussed it, they realised it was a good reminder of things they might come across but perhaps wouldn't necessarily identify at first glance as an AML issue.”

“Paying the same rate to all staff, regardless of their role, is possibly one of those things that people wouldn't necessarily have seen as a red flag,” she says. “But they now realise that this could indicate something as serious as people trafficking.”

“When you're regularly processing things coming in and going out, which is what a payroll department, by its nature, tends to be doing, it can be difficult to stop and think,” she suggests. “But that’s where the film helped: people had time to stop and think about what they look at every day, and why it's important to consider exactly what they are processing.”

The right balance