All Too Familiar, which was produced by ICAEW in collaboration with HMRC, focuses on how accountancy firms can put themselves and others at risk if they fail to carry out proper anti-money laundering (AML) checks and due diligence. It is designed to provide practices of all sizes with an innovative and engaging way of supporting in-house training.
“We’ve always found it hard to get staff engaged and interested in going on AML training courses, despite their necessity,” says Chris Beeston, Tax Director and money laundering reporting officer (MLRO) at Geens, a Stoke-based firm of Chartered Accountants.
“So when we heard about the film, we decided to see if we could get people more on board in this area and more engaged with the issues,” he explains.
“If the tax team go on a tax course, they like tax, so they enjoy it, and then they start talking about it between themselves, during the break or in the car on the way home,” he adds. But with AML training, whether face-to-face courses or online webinars, he has found it difficult to replicate that level of interest and engagement. “AML training has too often been something staff have been reluctant to attend or have endured,” he says.
Chris used the film to deliver two training sessions, which covered all members of the firm. “We had 13 people in one session and eight in the second,” he explains. “I didn’t lead them too much; we just put the film on and let people watch.” Attendees then split into smaller sub-groups with different issues to discuss, and then each of these fed back to the other groups.
During the discussions, the groups used ICAEW’s learning support materials, which include a list of questions to prompt discussion about scenes from the film.
“We photocopied the supporting questions and removed the answers that were underneath, so no one could see these. People therefore got to have a go at coming up with the answers first before they knew what they should be.”
“We wanted to stimulate conversation,” he stresses. “And the conversations certainly kept moving as we discussed new circumstances and real world situations relevant to our firm’s client base and the situations we may face.”
One of the aspects Chris liked most about the film was that it didn’t try to answer all of the questions. “There was plenty for us to discuss afterwards,” he says.
“That was very clever,” he adds. “It could have been portrayed in quite a linear manner where it was obvious that someone had ignored all the rules. Instead, we were asking ourselves ‘In those circumstances what would we have done?’”
“We had lots of questions and discussions about the person in the film who headed up the payroll,” he adds. “Had she actually done anything wrong, and if she had, how bad was it? Because you only saw snippets of scenes.”
This open-endedness was part of the reason Chris chose not to share the short follow up video that explains what happens to the characters afterwards. “I thought the discussion we, as a team, had ourselves was of more value than actually finding out what happened next,” he says.
Don’t miss it
Getting people talking in this way has already produced practical benefits for the firm. “We had team members suggesting improvements to our procedures; these came out of the film and they were good suggestions,” he says.
“Obviously we've already got robust procedures for new clients, but they can always be improved, and we are now making changes based on these suggestions,” he explains. “And it came from them, rather than from me. That’s when you know it’s worked. Rather than my deputy and I imposing what we know needs to be done, it made our team members think enough about the risks to the firm and the wider risks to start thinking how we could do things better.”
“It’s all been very positive,” he says. “And I think one of the reasons it has been so beneficial is that it was so different and so fresh. It got my team talking, and we probably talked about it for as long as we were actually doing the training exercises. We had two and a half hours talking to a staff team about money laundering, which is a big win from my point of view.”
“As a firm we’d highly recommend it,” he adds. “And that’s not just my opinion. The group who did the first film session were already telling the second group: ‘It’s actually really good, so make sure you don’t miss it.’”