60 seconds with… an AML Risk Manager

This month we sit down with Jenni Rodgers, the Law Society of Scotland’s Anti-Money Laundering (AML) Risk Manager, to discuss the complexities of AML and the Society’s upcoming plans…

Tell us a bit about your career so far…

I grew up in a mining village in West Fife. After schooling in the Kingdom, I went to Stirling University and graduated in 2017 with a degree in Scots Law. Since I was young, I intended to practice law. I dreamt about wearing the gown and taking to the courts, but when I was offered a compliance related role with HMRC, this fitted with my personal life, I shelved the gown… for now.

HMRC was my first “adult” job. I worked in their fraud investigations directorate, with a brilliant team which carried out HMRC’s role as statutory AML supervisor. The role presented that perfect mix of investigative and legal work for me. What can I say…I was hooked on sleuthing and the MLRs (that much that my parting gift was a hardback copy of the MLRs!). 

I went on to work with a global law firm, as a financial crime & risk adviser. I was where I always wanted to be, working for a law firm. Again, a role with a great mix of investigative sleuthing and legal work but also with that exposure in the profession that I always wanted. Here I picked up so much on a whole host of things compliance related streams. AML, anti-bribery & corruption, tax, sustainability, and financial sanctions compliance etc. You could say I became a “jack of all trades” in all thing’s compliance related.  

I joined the Society in March 2022. When the opportunity arose to combine my previous experience and work with the statutory supervisor for the Scottish solicitor profession, I had to take it. I came in with knowledge and experience from the other side of the fence and quickly took to the role, picking up inspections, liaising the AML Certificate, providing guidance on financial sanctions compliance etc.

I really enjoy providing guidance on AML best practice and other financial-crime related issues through our inspections and materials we publish on our website etc. Whilst our role sees us deliver some tough news to firms, there is a really nice side of regulation where you see the penny drop and you’ve really helped a firm understand their requirements. In this role, I truly feel like I am making a difference.

Its been a busy start to the year with the HM Treasury launching a consultation on Money Laundering regulations, could you share what’s the Society’s AML plans are for 2024?

Well firstly, regarding that consultation relevant stakeholders at the Society are liaising and will respond to the latest one regarding improving the effectiveness of the MLRs. We have had our fair share of consultations recently but it shows the importance of AML and how fast paced change is in this area of compliance.  

What are we up to as a team? Currently our small team have around 25 inspections on the go and around 8 in the pipeline for this year. This may change if we need to respond to any emerging risks.

Alongside our “BAU” we are launching our latest thematic on Suspicious Activity Reporting in May. My colleague Dale Trahms & I are coordinating this and we are really excited to better gauge the professions understanding of the SARs regime. This has been something we have been liaising with the National Crime Agency on and they have highlighted some areas that the profession need to work on.

The profession may have seen my name on the AML Certificate emails this year. I will be analysing the returns from May and publishing results later in the year from this. This is a crucial tool in our statutory obligations to deploy a risk-based approach and we thank all firms who complete & return this annually.   

We have some plans in place for some more educational pieces such as blogs, we are sharing the “All Too Familiar” video with further training materials, we will attend some faculty meeting and publish more AML round-ups to keep the profession up to date.

To sum up the rest of the team:

Our Head of AML, Graham Mackenzie, has just taken the role of chairing the AML Supervisory Forum.

Dale is also taking on her AML Diploma with the ICA.

 Stewart Rowles has joined us in the past few months and he will be reviewing our “BOOMs” process to make sure this is fit for purpose.

Emma Cairns is approaching a year in role and will be coordinating our third tranche of AML Attestations ASAP.    

It is all go in our team!

AML can be a tricky subject to navigate, what would you say in particular to high street firms tackling AML compliance?

High street firms tackling AML compliance face a lot of challenges and complexities…and we absolutely recognize that. It isn’t easy doing the day job and worrying about AML.  

I would say do not underestimate the basics. Read the MLRs, the Legal Sector Affinity Group Guidance and our Sectoral Risk Assessment. Get familiar with and implement the LSAG Compliance Principles – this is vital.

Start with your Practice Wide Risk Assessment, conduct a comprehensive one which will inform your Policies, Controls and Procedures (PCPs). Then implement a tailored set of PCPs. Make use of the materials on our website for this, in particular our PCP Thematic which highlights best practice tips.

Review these regularly. Why not use the AML Certificate as a trigger starting point for this?

Stay up to date with regulatory change by subscribing to various email alerts, read the material we publish in Lawscot News and on our website and keep connected with your peers.

More generally, if you could give one piece of advice when it comes to AML what would it be?

Providing comprehensive and tailored training to all relevant staff is your best line of defence. But, it is also important to follow this up by asking how you assess the success of the training. Do not rely on a regulatory inspection to pick up your weak areas in compliance, make sure you assess effectiveness of your PCPs in practice.   

You’ve been at the Law Society for 2 years, what has been your personal highlight?

I have a few I just have to mention. Speaking at the annual conference in 2023, attaining my AML diploma and raising funds for our chosen charity are standouts.

But I absolutely love presenting to cohorts of diploma students about AML. I really enjoy sharing knowledge and seeing students realise how AML fits into their future role in the profession. After all, they are the future, and it is a fantastic opportunity to help shape that future.

What keeps you busy outside of work?

My wife runs her own little cake making business and I take my role as chief quality assurance officer very seriously.

When I get the chance, I go to the football. I follow Dunfermline Athletic and Liverpool.

I also have a new passion…motorbiking. If the sun is shining, I will probably be out on the road.

I volunteer as a Panel Member for Childrens Hearing Scotland, a role I am incredibly proud of and really encourage others to consider.  

My wife & I go to our little spot of heaven on the Isle of Lismore most holidays. This time of year, is our favorite. Plenty of beautiful flowers, fresh lambs & the sound of summer calling.