Trusted Circles, Quiet Intentions: AML Lessons from the Gunpowder Plot

Each year on 5 November, we pause to remember a dramatic moment in English history.

But beyond the fireworks, the Gunpowder Plot holds a quieter lesson - one that speaks directly to the work of compliance, professional judgment and the risks that arise in familiar places.

The plot was not the work of outsiders.

It was developed and enabled by people of status, education, and means - individuals who moved comfortably within society.
Men of land, lineage and influence.

Men who were trusted.

The conspiracy grew not through public declarations, but through private conversations, discreet introductions, and the reassurance of relationships.

It was, in essence, a network built on comfortable familiarity.

And that is where the AML lesson begins.

In the professional world, there is a natural inclination to trust those we know — and those known by extension through colleagues, chambers, private client circles, business contacts, and family networks.

A client recommended by a trusted partner.

A matter introduced by a trusted professional who has worked with the firm for years.

Funds described simply as “family money” or “long-standing business interests.”

These situations feel safe.

And so, scrutiny softens.

Questions are asked more gently — or not at all.

Assumptions fill the space where verification should sit.

But as the Gunpowder Plot reminds us:

And familiarity is not a risk assessment.

Risk does not always arrive with flashing signals.

Often, it is polite, articulate, well-presented and socially integrated.

This is why strong AML frameworks must extend beyond documentation to culture:

• The confidence to ask, even when it feels awkward.

• The willingness to verify, even when someone is vouched for.

• The discipline to separate professional courtesy from professional obligation.

The plotters relied on:

• Shared social identity

• Mutual reassurance

• Reputation acting as a shield

These are precisely the dynamics that can obscure the origin of wealth, beneficial ownership, and the true purpose behind transactions today.

Professional services firms are particularly vulnerable because much of their business is relationship-led.

This is a strength - but also a vulnerability.

What we learn from history is that red flags rarely appear as red flags at first glance.
They often look like:

• A trusted name

• A warm introduction

• A familiar accent

• A quiet promise that everything is in order

Professional scepticism is not cynicism.

It is simply the ability to pause, step back and verify.

The Gunpowder Plot was ultimately revealed by a single act of disclosure - an anonymous letter raising doubt, prompting investigation, and preventing catastrophic harm.

In today’s landscape, that mechanism is the Suspicious Activity Report.

Internal and External Report should be accessible, clear, and all staff members are aware of.

Internal and External Reporting Mechanisms are the cornerstone of professionalism and strength. 

Reporting is not an accusation.
It is a safeguard.
A signal that something requires deeper clarity.

The courage to report - even when the matter is socially or professionally close - remains one of the most important tools in preventing harm.

The lesson is not dramatic.

It is thoughtful, measured, and clear:

Risk can reside in the familiar.

And the most powerful AML control is a culture that supports confident, courteous challenge.

Firms benefit from:

• Robust onboarding frameworks grounded in evidence, not assumption

• Clear source of funds and source of wealth methodologies

• Training that strengthens professional judgment, not just procedural awareness

• Independent Regulation 21 reviews that test both systems and culture

These are not administrative burdens.

Professional courtesy needs to be turned into Professional Obligation - ensuring that verify and carry out your AML obligations even in circumstances that would have otherwise have provided you with comfort. 
They are the safeguards that ensure your firm remains trusted - not simply trusting.

We can help you overcome cultural familiarity and challenge your systems:

• Regulation 21 audits and AML framework reviews - that the purpose of a Regulation 21 Audit is to test the systems and culture - so you are not just trusted not trusting

• File reviews and remediation programmes

• Source of funds / source of wealth methodologies

• Workshop

Always discreet.
Always tailored.
Always grounded in practical, real-world application.

Are services can be a tool to dislodge familiarity bias.

If a quiet conversation would be helpful, I would be pleased to schedule one.