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Switching the dial

Author: Professional Standards Department

Published: 22 Dec 2022

ICAEW’s anti-money laundering (AML) educational drama All Too Familiar is being used by firms of all sizes to support in-house training. Caroline Smale and Simon Morrison from Bishop Fleming tell us how the film tapped into people’s emotions and changed how staff think and feel about AML.

ICAEW’s anti-money laundering (AML) educational drama All Too Familiar is being used by firms of all sizes to support in-house training. Caroline Smale and Simon Morrison from Bishop Fleming tell us how the film tapped into people’s emotions and changed how staff think and feel about AML.

All Too Familiar, which was created in partnership with HMRC, explores a fictional accountancy firm’s relationship with a long term client who receives a significant injection of money to support his ailing restaurant chain.

Through its relatable characters, the film shows how familiarity can affect professional scepticism, and what can go wrong when people fail to carry out proper client due diligence.

“It really made people feel something,” says Caroline, Bishop Fleming’s Regulation and Compliance Partner. “And just making people feel that emotion means it stays with them; it triggers something in their brains.”

Polly Brock, a Tax Executive at the firm’s Exeter office, agrees. She attended one of the firm’s AML training events centred around All Too Familiar and found the film “very powerful and far more memorable than a traditional presentation”.

“The characters illustrated the emotional consequences of failing to apply professional scepticism, which got our group talking,” she explains.

“We were all familiar with the legal and reputational consequences from other training sessions but often we don’t think about the personal impact, or potential links to exploitation.”

Getting people talking

Bishop Fleming has around 500 staff working out of eight offices across the South West and West Midlands. It had already used ICAEW’s previous educational dramas False Assurance and Without Question for audit training, so when All Too Familiar was launched it was keen to use it for AML training.

The firm has been showing the film during dedicated workshops at its offices, with around 40 to 60 people attending each event. “We had sessions with all service lines across all different areas and levels of the business,” explains Caroline. “So we had a cross section of people participating.”

As well as screening All Too Familiar, the firm showed the film’s launch video and the follow-up to the main film, which explains what happens next to the key characters.

“In between, we had some discussion groups,” says Caroline. “We picked out some of the questions from the resources pack that we thought were most appropriate for us and we got people to discuss those in these groups.”

Bringing people together across service lines pulled out the different things people consider during their work, and the varied approaches they take. “People see things from different points of view, and that cross pollination of ideas is a good thing,” says Caroline.

As a workshop participant, Polly also appreciated the differing viewpoints. “I was in a group with a manager and a partner split across central finance, internal audit and corporate finance so we were able to share very different stories and perspectives,” she says.

The film’s storyline particularly highlights some unexpected developments in the restaurant chain’s payroll. “Having the payroll team come along to the Bristol event meant that they got more involved and asked more questions,” says Simon Morrison, Audit Partner and MLRO at Bishop Fleming.

“It was interesting to get their input and bring them into the mix,” he says. “As MLRO, I’m always thinking about how best to make sure they have confidence that they're doing everything they should be doing.”

Hard hitting

Caroline thinks part of the film’s power is that it “switches the dial” from form filling and ticking boxes to making people think about the repercussions of not doing something properly, and encouraging awareness of what they should be doing. “People really started to think: how would I feel if I got this wrong?” she says.

For Simon, the video follow-up to the main film, which explains what happens next to the key characters, was particularly useful in helping to drive home personal responsibility by showing that there are repercussions for individuals. “You want everyone who watches the film to watch that last part,” he says.

The realistic scenarios in the film also resonated. “There were the passing comments in the corridor where people are in a rush and the manager is trying to get the partner to sign off a form,” says Simon. “Staff recognise those situations, and see that those rash decisions, where you kick something into the long grass because you’re too busy, do actually have repercussions.”

Something else that rang true was how the characters in the film got excited and enthusiastic about the prospect of a new client and just wanted to start the work, rather than pay attention to the necessary processes and procedures. When people are caught up in the excitement of new business, it can sometimes cloud their judgement.

Practical outcomes

The key messages in All Too Familiar have already translated into practical outcomes at Bishop Fleming. During the afternoon after the training session, a member of staff was asked to contact a potential new client, and they decided to do a quick online search of each of the company’s directors individually before making the call.

Because smart searches are performed later in the process, they wouldn’t normally have looked into the directors’ background in this amount of detail when simply arranging an introductory meeting. But after they had spent five or so minutes looking into each director, their research immediately raised some concerns. They reported these to the AML team to consider.

“We decided not to take it further with that potential client,” says Caroline. Practically, that meant the firm hadn't wasted time having a scoping meeting or making further checks.

“It also meant we didn’t have that embarrassing situation where we'd gone so far down the line with the client and then had to say we couldn’t act for them,” she adds. “And all of this was a direct outcome of watching the film for one of our newly qualified members of staff.”

Making a difference

One of the key messages Simon is always trying to promote is that procedures and policies around AML are not just about compliance but more importantly about “making a difference”.
“The real reason these rules are there is to stop people getting exploited and stop criminal activity; it's that wider fight against economic crime, ” he says. “And that message came over in the launch video and also through the film.”

Bishop Fleming wants to reach the point where everyone in the business has watched the film and received the training. “We've probably reached 30 to 50% of our people so far,” says Simon. “But I think there's value in it for everyone.”

“We've just acquired an office in Cheltenham, so we intend to take it there and show it to the whole staff,” adds Caroline. “It’s a brilliant tool, and it's something that's a bit different. It’s not what people expect.”

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