“A lot of work around AML is about raising awareness and making sure the culture is right,” explains Howard Ringrose, Audit and Advisory Partner at BHP Chartered Accountants. “So that if something doesn't look or sound right, then it makes people think about their responsibilities and what they need to do.”
“We felt the film really got across the message that: ‘Wow, this could happen at any firm if you're not careful’,” he adds.
“It felt very realistic,” he explains. “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.”
Getting people watching
Ringrose had been looking for a new form of AML training for staff and partners, so All Too Familiar ticked all the right boxes.
Once he’d decided to use the film, the next step was to figure out how to use it effectively across around 400 staff.
In the end, he took 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.”
Thought provoking
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.”
Getting non-client facing staff involved has already paid off in terms of strengthening the AML culture across the firm.
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.”
Easy sell
“Overall, we’ve had really positive feedback,” he says. “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.’”
“It was also very professional; one of our staff members even likened it to watching an episode of the BBC drama ‘Line of Duty’.”
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 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.