Next to this the group lists countries with statutory banking secrecy that also have wealth management markets. No examples are offered but the FATF's list of “high-risk and non-co-operative jurisdictions” has a few states on it that RMs might want to consider. (These fall into three camps. Among the “jurisdictions with strategic deficiencies that have not made sufficient progress in addressing the deficiencies” are: Ecuador; Indonesia; Turkey; Vietnam; and Yemen. In the second camp, that of “improving,” lie Argentina and Kyrgyzstan. In the third class, that of sanctions, Iran is in a class of its own.)

• Countries with statutory banking secrecy.
• Countries where corruption is known, or perceived, to be a common source of wealth.
• The frequent insistence of HNWs on transmission of funds in high values rapidly between accounts all over the world.
• The use, by persons unspecified in the notes but presumably private banks on their own initiative, of concentration accounts – multi-client pooled/omnibus-type accounts.
• Private banks' tendency to extend credit to clients while using potentially “dodgy” assets as collateral without researching their origins.
• HNWs' tendency to conduct commercial activity through personal accounts to deceive the bank or the RM themselves.
• The common use in wealth management of collateralised loans without disclosure of the identity of the guarantor, if there is one.

An appreciation of these risks will be of massive help to a private bank's compliance officer – or even an RM – in the formation of legitimate suspicions that might lead to a suspicious transaction report being sent off to the Serious Organised Crime Agency.

The RM faces a quandary: what is a suspicious transaction? In most European Union countries for most of the time they have been obeying EU anti-money laundering statutes - it was synonymous with an unusual transaction. The JMLSG still makes the odd pronouncement in which it conflates the two, although it should not because banks have long been required to take a risk-based approach to money laundering problems. The MLRO always has the last say about the sending of a report, but the JMLSG expects RMs to be often the first source of suspicion because they operate on the front line of money laundering control.

This is evident in point 5.4, which says that “the role of the relationship manager is particularly important to the firm in managing and controlling the money laundering or terrorist-financing risk it faces.” In 5.5 it states that he or she must “at all times” be aware of the dangers of “becoming too close to the client.” He or she should guard against a “false sense of security,” presumably the firm's security from the threat of regulatory fines or worse. He/she should also guard against “undue influence by others” (this is not explained) and “conflicts of interest” (also unspecified but presumably this refers to the bank's impetus to make a profit by treating the HNW as a customer when it should be thinking instead of treating him as a suspect).

The RM should also be worried about his/her personal safety (para 5.6). This is not an idle warning; criminal networks have been known to gain favours from high street banking staff by threatening them with beatings. Some years ago a French private bank reported its findings about a gypsy network to the police. The head MLRO told a conference that “the gypsies” in France could use their contacts in the police to find out the whereabouts of anyone who had moved to escape intimidation and as a result, the MLRO was sent to New Caledonia in the Pacific to keep him from harm. Para 5.6, some might think rather naively, states that firms should have suitable internal procedures to require staff including RMs to report the fact that they have been menaced and a policy for reporting such incidents to the police. RMs, it adds without giving a reason, should never handle cash.