Driving Successful AML Change

By Cleo Shortland, Director of VPO Risk Management


There are two things for certain regarding change…..It is inevitable and uncomfortable for our people.

A degree of pain comes with additional regulatory changes introduced due to extra work tasks to meet obligations and increased costs to the business. It can be difficult for business owners to see the benefits of regulatory change, contributing to a culture resistant to regulatory change. This is why adopting change management is beneficial to those who find themselves captured by AML/CFT and must adopt an AML/CFT programme.

What is change management?

Change management involves gaining stakeholder buy-in to bring your people along on the journey of organisational change.

Change management includes the disciplines of:

Psychology, behaviour, engineering and systems thinking

While incorporating five key principles:

  • ROI on change – what are the benefits of change?
  • Get your cheerleaders for change on board – who in the business can help you drive change?
  • Change readiness – is there any resistance to change? What are the roadblocks?
  • Change strategy – how can we get people affected by change to care? What’s in it for them? Roll out your plan.
  • Sustained performance – how do we prevent old behaviours from returning?

Change management is a methodology used for any project that involves change and people as it addresses the deliverables that involve a human element.

For example, an AML/CFT consultant may be asked to put together an AML/CFT programme and roll out some training for an organisation. The programme is what we would consider the project, and the team engagement and effectiveness of the programme is how we would measure the success of how well we managed change.

In my experience, I have found that team members who are passionate about why the AML/CFT regime is in place can develop cultures that are too engaged and motivated when carrying out AML/CFT activities, and this is typically my starting point.

How can you determine change readiness?

The most common mistake I see is the assumption that the team affected by change is on the same page before putting a programme together. Getting everyone on board requires doing some research on (and usually speaking to) those affected by the change.

From there, gaining an understanding of any resistance to change and coming up with a strategy to get everyone on board is your most useful starting point. Putting the extra time in the beginning, can save a lot of miscommunication and resistance down the track.

I also consider why I have been engaged. If it is due to a formal notice by their Supervisor, the team is typically ready and willing to adopt change.

However, if it is due to the obligation to put a programme in place and the team hasn’t been through the audit process, there is more resistance to change, which is not always the case but provides insight into how teams may feel about adopting new activities.

How do you learn the methodology of change management?

Change management is made up of those who have:

  • On the job experience: usually through corporate environments or leadership roles where you are rolling out a high volume of change projects to innovate continuously.
  • A formal qualification: you can sit a certification for formal theoretical training on how to roll out change management projects.
  • Additional to the above, a highly experienced change management practitioner can agree to mentor you (as I was lucky enough to have). Making your own mistakes is part of the journey, but if you can learn from others, that is always a bonus.
  • There are also great books, resources and training available on change management. Some of the technology and cultural change management resources can be easily adapted and applied in the AML/CFT space.

Creating a positive culture around AML/CFT

Change management is a common methodology in many sectors but seems to be under utilised in the risk management space. Change management is a methodology that I am passionate about as I have found it highly effective in driving positive change around AML/CFT. Still, I have seen many AML/CFT practitioners drive successful change using alternative approaches that are too highly effective.

Creating an industry where we are all contributing to creating a positive culture around AML/CFT should be our objective, and change management is one option on how you can achieve that objective. 

Read more about driving successful AML change with our checklist on ‘How to do Privacy right‘.


Cleo Shortland VPO Risk Management

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