A card game has been created to help firms tackle the challenge of training and maintaining understanding around source of funds. The brainchild of two compliance consultants, the game “helps fee earners and support staff translate their decisions quickly into a documented analysis” for evidence say its creators.
Tom Lyes, formerly of source of funds technology solution Armalytix and now director of Tom Lyes Consultancy, and Steve Brett of E3 Compliance Training, say the game brings together 10 years of development with the in-depth knowledge of the realities of source of funds.
Source of funds continues to be a point of non-compliance for firms, routinely highlighted by SRA desktop audits. But the issue, say Lyes and Brett, is not “because fee earners get the analysis wrong, but because they never write it down and tell the story.”
Explains Lyes: “When I speak to AML consultants or compliance heads, the fee earner rarely gets the analysis wrong. What’s happening in practice is the explanation and storytelling is the real gap. That’s what this game trains for.”
Playing in pairs, players look at a scenario with one player documenting the source of funds decision while the other player evaluates it. They then switch places. As the scenarios build, the players build their ability to record their source of funds evaluations with the feedback from a peer.
It is this feedback that drives the learning, adds Brett – feedback that is missing or divorced from the initial decision in the office. “We need people to engage with the challenge of documenting their thinking on source of funds and develop habits to reduce the friction. Games are a great way to help people focus on building skills they can use straight away when they return to the office.
“By helping people see the gap between their thought process and what they document together with tools to reduce the friction, we help people gain the skills and habits to quickly create short and effective documentation.”
The game is played with a facilitator guiding discussions and highlighting key learning point with sessions typically last 60-90 minutes.

















