Don’t be a cookie jar for your consultants


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AML expertise independent of consulting drives best practices

By Frank Cummings, CEO of AML Partners

Do you ever feel like you are getting played by your consultants? Like your business and your best interests are really just one big cookie jar full of their billable hours? No doubt a more accurate question is not whether but how often you feel like your institution is their cookie jar.

That was my overwhelming first reaction this morning when I read a consultant-sponsored ‘expert insight’ from a major financial-news publication. Key word: Sponsored. Secret key-words: Money grab.

In this advertisement thinly masquerading as regulatory expertise for financial institutions, the author touted the formation of a new “advisory council” to promote best Compliance practices in the financial-services industry. Except that these are “best practices” that will be defined by a few in-on-the-scheme consulting companies and their tech vendor.

Their pitch focuses on their so-called independent guidance to their consultants about current and future regulations and best practices—but the lifeblood of most consulting firms relies on their current business creating ongoing business ad infinitem.

Anyone whose industry relies on consulting firms has experienced this—you bring in a consultant to help fix one issue, and somehow they find ten new issues that require five more years of work by that same consulting company. One things leads to another and you may as well add them to your corporate health insurance and retirement plan.

As Compliance professionals know, industry standards must be created by the industry and those who regulate it—not the consultants who seek to profit from consulting on those regulations. So-called best practices created by consultants will almost invariably be created for the benefit of the consulting industry. Not for the benefit of the industry they are claiming to serve.

That’s not the fault necessarily of the consulting industry—it’s more a part of the natural landscape. But that’s why it’s so important to keep your eyes wide open with claims of so-called advisory councils—and for institutions to maintain their own internal expertise and good judgment.

Part of why this matters so much is that the stakes are so high—for financial institutions who have to make wise decisions about time and resources committed to Compliance, for countries around the world battling the scourge of financial crime and money laundering, for nations battling the endless and grave threat of global terrorism.

For all those reasons, it makes sense to keep one’s eyes on true best practices and Compliance problem-solving—and not just surrender to being the biggest cookie jar.


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