Recognize a mismatch between intentions and outcomes Bypass or deny the mismatch Cover up the bypass Defensive routines produce mixed messages at two levels: Level I - Denial Routine recognize a mixed message, inconsistency, gap, or mismatch between intentions and outcomes act like it is not a mixed message or inconsistency, deny that defensive routines exist, bypass embarrassment and threat Level II - Bypass Routine make this bypass action undiscussable cover-up the bypass make the undiscussable nature of bypasses undiscussable; cover up the cover-up Example of Mixed-Message A Mixed-Message, Outsider gets Invited to a Meeting:
These sectors were selected for this study because they were highlighted as medium- or high-risk areas in the National Risk Assessment of Money Laundering and Terrorist Financing NRA The NRA promotes the idea that progress has been made in better understanding the role of these sectors.
However, this paper finds that obvious intelligence gaps remain. Through documentary review, interviews and workshops, this research seeks to understand the reasons why, despite a concerted effort by the government and law enforcement agencies, the intelligence base needed to tackle money laundering involving professionals in the UK remains patchy.
Evidence collected highlights a number of cross-cutting systemic and structural issues relating to the application of the AML regime across the professions considered in this paper, as well as some specific sectoral issues.
This research identifies inadequacies in the guiding government narrative, intelligence structures and the role of the AML supervisory regime in relation to intelligence sharing. These result in poor public—private intelligence flows, including through the Suspicious Activity Reports SARs regime, and under-utilisation of non-SARs information and intelligence.
The narrative should be restructured along activity lines to overcome this fragmentation. Furthermore, the vocabulary used to describe the nature of professional service provider involvement in money laundering needs to better reflect the nuances between complicit, complacent and Using the gaps model of service actors in the system so that interventions can be better targeted.
This paper also examines the nature and scale of information sharing relationships between the public and private sectors: Here the relationship with the non-financial sectors lags behind the more dynamic relationships emerging with the banking sector, for example under the Joint Money Laundering Intelligence Taskforce JMLIT model.
Furthermore, establishing a network of trusted sector experts, perhaps via the National Crime Agency NCA Specials programme or formal secondments of staff, who could use their knowledge on tactical and strategic levels to create a more dynamic model of information exchange, would be beneficial.
This weakness risks undermining AML compliance overall and reducing the quality and quantity of SARs submissions from the regulated entities in these sectors, which are regarded as inadequate by the authorities.
Its key initial challenge will be to embed a culture of intelligence and risk within PBS where this does not currently exist.
There are high — and possibly unrealistic in the short term — expectations that OPBAS will provide the solution to poor intelligence flows between PBS and law enforcement.
Early communication of this message to PBS and law enforcement will be key to managing expectations, but OPBAS should also move quickly to explain how it sees its overall function of facilitating intelligence flows. Although this paper recognises that there will frequently be more than one profession involved in a transaction such as the purchase of property or service such as the formation of a companyit is critical to understand the factors specific to individual sectors that undermine their contribution to the intelligence picture.
This paper examines factors specific to each of the four sectors by considering the findings of the NRAthe SARs yield from each sector, industry cultures and intelligence-sharing relationships.
Accountancy Services Providers This paper finds that a one-size-fits-all approach to intelligence gathering in relation to such a large and diverse sector is failing.
While the NRA went some way in refining the risks to specific activities and sub-sectors, it did not go far enough. This paper specifically recommends developing the understanding of the threat in relation to unregulated accountants who sit inside the AML regime and the accountants in industry outside the AML regime.
It is debatable whether the number of SARs from this sector is too low as the government claims. However, this paper recommends: This paper recommends establishing a specific intelligence-sharing forum for this purpose, and recognises the untapped potential of industry experts, who are well placed to inform the intelligence picture at strategic and tactical levels.
Better exploitation of this expertise, perhaps via the NCA Specials programme, is recommended. Legal Services Providers While the NRA better defines the risks of specific types of activities performed by legal professionals, it does not adequately identify which parts of the higher-risk sub-sector solicitors are most at risk.
Furthermore, case studies detailing evident complicity or complacency do little to help those making an effort to comply. Refining these typologies would go some way to improving risk awareness and resulting SARs submissions. With regard to information sharing, this paper suggests that, while the supervisory environment for the legal profession also consists of a number of different bodies, this is due to geographical and professional distinctions and is thus easier to navigate for law enforcement.
However, information sharing between law enforcement and the sector is not on the dynamic footing needed to react to increasingly complex money laundering.
This research identified the need to design more bespoke forms of information sharing with legal professionals, outside the confines of the SARs regime, to improve collective knowledge.
This paper asserts that the low risk rating assigned to estate agents in the NRA will do little to remedy this situation. There is also a clear need to establish a more effective means of reaching out to the sole traders and micro-businesses that dominate this sector.
The key to securing better intelligence engagement from the sector lies in tackling two key issues — the industry culture around AML and poor AML supervision registration rates.Action Science is a strategy for increasing the skills and confidence of individuals in groups to create any kind of organization and to foster long-term individual and group effectiveness.
started with the concept of service quality and has demonstrated the model of service quality gaps.
SERVQUAL as an effective approach has been studied and its role in the analysis of the difference between customer expectations and perceptions has been highlighted with support of an example.
Research demonstrates that African-American children enter kindergarten almost nine months behind their White peers in math and seven months in reading, Hispanic children about one year behind, and low-income students enter months behind.
This can be attributed to the opportunity gap, when one group of students has fewer opportunities to optimally learn and develop. There are many types of Service that the Customer Service Gap Model describes. This article and podcast describes the model and how to plan for it. Using DNS zone file syntax, the service instance "A web page" is advertised using one PTR record, while the instance "A printer's web page" is advertised using two: the primary service type and the additional subtype.
1 The Gaps Model of Service Quality and its Impact on Customer Satisfaction Abstract: The Service Quality or Gap model (SERVQUAL) has been recognised as an essential tool in.