Is trust enough? AML and professional scepticism

All Too Familiar, ICAEW’s third educational drama, focuses on how firms can put themselves and others at risk when they do not conduct proper anti-money laundering (AML) checks and due diligence.

The film’s main aim is to challenge professional mindsets. In particular, it provokes discussion about how long-held relationships can cloud judgement, leading firms to miss red flags and even overlook suspicious behaviours.

“There were two reasons we chose this subject,” explains the film’s writer,” Duncan Wiggetts, Chief Officer, Professional Standards Department, ICAEW. “First, ICAEW is one of the largest supervisors of AML in the UK. We supervise around 11,000 firms, so it’s very important to us that our firms understand exactly what they should be doing. We want them to be compliant, and the route to that is effective education, so we’re hoping the film will help with that.”

The second driver was Wiggetts’ representation of the accountancy profession at the Economic Crime Strategic Board, which brings together government agencies, financial regulators, banks and professional bodies in a forum chaired by the Home Secretary and the Chancellor, to enhance the fight against fraud and other economic crimes.

Figures show that fraud has not followed the falling trend of other types of crime during lockdown periods. According to the Crime Survey for England and Wales there were 5.1 million fraud offences in the year ending September 2021, an increase of around a third (36%) on the year ending September 2019.

One of the key issues for professional bodies is how easy it is for their members to inadvertently assist  criminal enterprises. So ICAEW, working with HMRC, decided this was an ideal subject for an educational drama. “We wanted to help make accountants see how easy it might be for them to become professional enablers, so they stay alert and carry out all the compliance checks the regulations require,” explains Wiggetts.

Challenging mindsets

The drama opens with a conversation between Alex, the owner of Trivena, an ailing restaurant chain, and Jack, his long-term adviser and partner in a large accountancy firm. Alex tells Jack he has a new investor, Mika, a distant family member.

But, as the story unfolds, Jack and his colleagues, as well as a smaller accountancy firm owned by Jack’s long-term friend, Riley –  introduced at Mika’s request to reduce Trivena’s professional fees –  witness a series of changes after the injection of Mika’s money. These include an increase in revenue, payroll adjustments, and a high staff turnover.

These changes were initially put down to ‘new management, new ideas’ and dismissed. Jack had known Alex for a long time, Mika was a family member and Riley trusted Jack’s judgement and his referral of one of his longstanding clients.

It is only after Riley and Jack visit the empty restaurant, are repeatedly refused an introduction to Mika, and encounter other unexpected visitors, that suspicions are raised. But the question then is what will they do?

Throughout the film there are a series of red flags that should raise suspicions. “Individually these might not be sufficient to indicate money laundering,” says Michelle Giddings, Head of AML, ICAEW. “But the combined weight of all the factors set out in film creates that suspicion. During key decisions and actions, the characters fail to demonstrate professional scepticism.”

Keeping it real

As with ICAEW’s earlier films, the cast includes well known film and television actors. Alex is played by Bill Ward, who has had long-term roles in Coronation Street and Emmerdale, while Kasia Pelka, familiar from Brookside, Heartbeat and, more recently, the Channel 4 drama Before We Die, plays Riley.

“We hold out to get the best possible actors,” explains Wiggetts. “The better the actor, the more effectively they convey our message because they come across as credible and realistic in their roles. This means viewers identify with them, empathise with them, and feel their stress and their pain, which is how we drive the lessons home.”

Provoking discussion

All Too Familiar launches on 8 March and will be available to all ICAEW and HMRC-supervised firms, free of charge, for use in their internal training. At the launch screening, John Glen MP, Economic Secretary to the Treasury, will give a keynote speech. Other attendees will include Ruth Dearnley OBE, CEO of Stop the Traffik, and Simon York CBE, Director and Chief Investigation Officer, Fraud Investigation Service, HMRC.

The film is supported by a range of resources to help deliver training sessions and workshops. It is relevant for all accountants, but its focus on how longstanding relationships between clients and advisers can influence professional judgement means it can also engage a wider audience.

ICAEW and HMRC recently received a letter from the Home Secretary, Priti Patel MP, in which she welcomes the public-private collaboration behind the film and highlights its potential to challenge mindsets and provoke discussion around professional scepticism in the sector.

“The reason we make these films is because we believe people are more likely to remember lessons from what they’ve seen visually,” says Wiggetts. “And this is so much stronger than anything you can ever achieve through presentations or written learning materials.”

“You identify with some of the characters, you feel bad when things go badly for them and, in the future, if you’re thinking about starting work without doing all the right checks, you’ll remember how you felt about what happened to Jack and Riley.”

Resources

• Find out more about ICAEW’s training films.