So, you have your e-learning for Anti Money Laundry (AML) & Financial Crime. It seems good, staff are passing the regular tests and it looks like it is a cost effective solution.

Part of the problem, of course, is that most institutions are fighting last year's war and that e-learning is mostly reactive and static [as, necessarily are many policies & procedures]. For every $ financial institutions spend on AML structures, the criminals are spending as much [probably much more]. It is Black Swan stuff, presently we are looking for what we know. The attacks though, are coming from new jurisdictions, new people, new businesses, new tricks and unexpected insiders.

What can't be taught in an online course is the 'smell test', that 6th sense that something is not quite right, those little details not caught by the systems. The feeling that you need to ask more questions, dig a little deeper and put risk before revenue in daily work.

It's tough, how do you teach instinct? Well, in my experience, the only effective way is a face to face course, case study based and utilizing the experience of participants to look at real, recent examples of crime.

Someone on a recent AML course told me she had learned more about the subject in 1 day than in her whole banking career because it was real and she was able to discuss her issues with other colleagues from around the country. The right course with the right trainer, it is has the biggest impact and delivers lasting results - e-learning has its place but can it really teach you how to 'smell'?