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An easy sell for AML

Author: Professional Standards Department

Published: 17 Aug 2022

Firms of all sizes are using ICAEW’s AML educational drama All Too Familiar as a way of supporting in-house training. In our latest case study, we find out how the film has helped to strengthen and underpin the AML culture at BHP, one of the largest independent firms of chartered accountants in the north of England.

“We had already used a previous ICAEW film drama, False Assurance,” says Howard Ringrose, Audit and Advisory Partner at BHP Chartered Accountants. “We'd rolled that out a year or two ago within the audit teams and it was very popular.”

Ringrose is also BHP’s Money Laundering Reporting Officer (MLRO) so when he saw All Too Familiar he decided to use it to support anti-money laundering (AML) training within the firm. 

“We felt the film really got across the message that: ‘Wow, this could happen at any firm if you're not careful’,” he says. “And I think that is its power. It was also very professional; one of our staff members even likened it to watching an episode of the BBC drama ‘Line of Duty’.”

“It was really good timing too,” he adds. “I'd been looking for some new form of AML training for staff and partners. We've used training modules before where people see a video or some slides and then answer questions. But we wanted to refresh things, and this showed a potential real life situation.”

All Too Familiar, which was created in partnership with HMRC, is set around a fictional accountancy firm, Nickel Turner LLP, and explores its relationship with a longstanding client who receives a significant injection of money. It focuses on the consequences of placing too much trust in personal and professional relationships, and shows how easy it can be for firms inadvertently to become professional enablers of economic crimes.

Getting people to watch

Once he’d decided to use the film, the next step was to figure out how to use it effectively across the whole firm.

“There's a lot of material in there and we did consider having sit-down sessions with everybody," explains Ringrose. “But with about 400 people in our firm, we decided that would be rather too time-consuming. We needed to find a better way of delivering it.”

In the end, he chose a simple approach. “We posted a message with links to the film on the firm’s business communication platform,” he says. “And we asked people to watch the main film and the short ‘what happened next’ follow-up video.”

After viewing the two films, people went into their HR training logbooks and answered some questions. “We also asked them to go back to read our own policies and procedures for AML,” adds Ringrose. “They had to confirm they were familiar with these and knew where to find the information they might need, for example, where to pick up the template for a Suspicious Activity Report.”

“When they had completed the logbook tasks, they had to sign off that they had done so,” he says. “That created a record, so we were able to see when and how many people had gone in and watched the film.”

Ringrose made watching the film mandatory for all client facing staff, and recommended it to support staff.

“Some support staff help out with AML procedures, such as running electronic checks or processing new client forms,” he explains. “A lot of them did watch it and that was partly because the word got out that it's a really good film and very thought provoking.”

This level of staff involvement has already paid off. Ringrose recently received an email from a member of support staff who was double-checking processes for taking on new clients linked to an existing client. “She wanted to make sure she was taking the right approach,” he says. “And those sorts of questions might not have arisen if she hadn't watched the film. It showed me she has the right mindset.”

Driving home the consequences

All Too Familiar comes with a range of supporting materials, including questions to prompt discussion about specific scenes and a who’s who of the main characters.

“I used the various prompts and questions to draw out some of the key questions that we put into the training logbooks,” says Ringrose.

He found the ‘what happened next’ video particularly useful. “This is a very powerful way of driving home the consequences for the key people appearing in the main film,” he explains.

“Overall, we’ve had really positive feedback,” he says. Some of this was face-to-face through chatting to colleagues in the office, and other feedback came via email.

“I've got a couple of teams working for me and they were all talking about it, saying: ‘I've watched it; you should watch it; it's really good.’”

Real life scenario

As well as appreciating the quality of the drama, staff also found it easy to identify with the characters and situations.

“It felt very realistic,” says Ringrose. “When you were watching it, you had a sense that the structure of the firm, the way the partners acted and interacted, and the way they talked about things with clients, were very true to life. And I think that was part of the power of it.”

He also felt the inclusion of modern slavery in the storyline helped to heighten awareness that money laundering is often linked to other serious crimes. “That was a very useful topic to bring up,” he says.

Ringrose is currently reviewing BHP’s client take-on procedures as part of continually improving the firm’s policies and procedures. “These are already robust,” he says. “But we're always looking for ways to get better.”

The film has helped provide context and perspective during this review process. “It allowed me to stand back and say: ‘Right, are we doing everything we can so that the situation in the film will never arise at our firm.”

“A lot of work around AML is about raising awareness and making sure the culture is right,” he adds. “So that if something doesn't look or sound right, then it makes people think about their responsibilities and what they need to do.”

Easy sell

In future, all new BHP staff will be watching the film and updating their logbook in their HR record. “It will be part of the induction for new starters,” explains Ringrose, “alongside the other training modules they have to do.”

He says the nature and length of the film makes it particularly easy and practical to fit into the firm’s wider training and engagement activities for AML.

“We say to everyone: ‘We need roughly 30 to 35 minutes of your time to watch the two videos, and then to go into your logbook and fill in some questions’,” explains Ringrose.

“And from just that small amount of time, the impact is really powerful. So to me it’s a relatively easy sell. The whole production is fantastic and it’s exactly the sort of thing we need to see more of.”