With effect from this month, the Guernsey Financial Services Commission is to oblige people who have held the position of money-laundering reporting officer and/or money-laundering compliance officer at a banks and fiduciary firms to attend 'exit interviews.'

This is the result of a six-month pilot project. It will apply only to people who have left MLRO or MLCO positions at these institutions after 1 January. The regulators want to use these meetings to know more about the responsibilities and problems that people in these jobs face.

Sue Grossey, the well-known AML trainer, has written on this subject: "I know that there will be some who will say that it’s none of the regulators' business and it’s just meddling and it will encourage people to dish the dirt on unpopular colleagues, but I’m assuming that an MLRO thus summoned can simply say, 'I’m leaving for personal reasons' or 'I just didn’t like the work.'

"For an MLRO who is leaving because his workload is too great or because he is not receiving the support he needs from his board or because he has lost the will to fight the tide of money laundering that is overwhelming his jurisdiction, isn’t it right that the regulator should know that? Oh what I’d give to be a fly on the wall at those interviews.

"I very much hope that the regulator will (a) continue the initiative after the six-month pilot, and (b) publish the (anonymised) findings from these interviews. In the meantime, I salute the bravery and imagination of the GFSC."