- July 10, 2022
- Posted by: FCS Compliance
- Category: Blog
Find out more about the AML experts at FCS. In this interview, FCS PR Director, Alison Blease introduces you to Jonathan who, previous to FCS Compliance, was a detective for the police and became part of a team investigating corruption within the police service.
I’m here today with Jonathan Evans, Senior AML Consultant at FCS Compliance, who I believe has been with the business from the very start. Welcome!
Hi there! Yes, I joined FCS Compliance in 2019 and have been with the business some three years now.
Let’s go back to the beginning. Tell me a little about your career journey.
I joined the police force at the age of 19. Based in South Wales, I began in uniform before becoming a full-time detective. I then worked for several years on a homicide unit and then later as part of an internal anti-corruption team investigating corruption within the police service.
My final years in the force were spent working in a department that delivered disciplinary hearings for police officers that fell foul of the disciplinary code. In all, I spent 31 years in the police force.
That’s some career! It sounds as though the work was quite varied.
Yes definitely, from working with the fraud squad to looking after the Dalai Lama – and everything in between!
Are there elements of your police work that you bring to your current role at FCS?
One of the key qualities you need to work in fraud and homicide is attention to detail. The ability to seek out the detail in witness statements is crucial in bringing about a successful outcome to a case. And it’s the same thorough approach that I apply to client due diligence (CDD) at FCS. It’s making sure that nothing is overlooked before returning a report to a client, knowing that a job has been well done, that they’re AML compliant and good to continue with the transaction.
You joined FCS in 2019 when Jerry Walters (founder of the business) set the company up and were part of the original team.
That’s right back then it was just Jerry, Caroline, Jen, Malcolm and myself. We all more or less came from a law enforcement background and that really helped.
And what’s your role within FCS?
I look after the due diligence referrals that come in from our clients as well as drafting AML policy manuals and risk assessments. I also assist with Suspicious Activity Reports (SARs) that agents are often required to submit to The National Crime Agency.
And what are the key things clients need in order to be AML compliant?
They must register with HMRC, have mandatory policy documents in place, be adequately trained and familiar with the legislation and carry out appropriate due diligence on all of their transactions.
So where do people go wrong?
They can easily overlook things. It goes back to attention to detail. HMRC is particularly keen to inspect whether agents have been thorough in identifying the source of funds. After all, that is why the legislation was brought in. Be it a property or a work of art, has the source of funds been clearly established and is it clear how a purchase is being made?
Agents or AMPs (art market participants) often work with the same clients many times over, and it can be uncomfortable asking them for such things as a copy of their bank statement. But it’s something that we’re used to doing – it’s our job to ask those awkward questions.
What’s the one tip you’d give to professionals who need to be AML compliant?
Don’t apologise for being intrusive because that’s what the regulators expect you to be. You can’t be cautious enough when it comes to the transactions you deal with. HMRC have placed a high bar when it comes to due diligence and they will expect you to be compliant.
And what do you like about your job?
It’s got to be the variety. Every transaction is different. I’m particularly excited about the new art division we’ve just set up. The art market is so interesting, particularly in the way in which it crisscrosses international boundaries.
And I know you have a personal interest in the art world too.
Yes, I’m in the final year of completing an art history degree.
That’s seriously impressive, given that you’re working for FCS too!
Thank you so much Jonathan for taking the time to talk to us – it’s been fascinating.