Compliance conundrum

When the banker helps his head of compliance get out of having to do two days of charity work, he is forced to question whether it is a smart career move. MR BANKER

Banker of Last Retort

By Mr Banker

I was curious when my executive assistant told me that the Head of Compliance had arranged a meeting. I haven’t made a decision since 1994 (and only then by accident) – so our paths would not normally cross.

It became clearer when he stepped into my office. Forced bonhomie and strained joviality (as subtle and natural as a tap-dancing hippopotamus) led to the conclusion that he wanted something. And when he turned the conversation to our community participation program – which requires executives to spend at least two days volunteering in the community – it became clearer still.

(Sometime ago after reading about how community service organisations were swamped by volunteers from large corporates when what they really wanted was cash, I looked into the matter further. I was able to arrange a mutually beneficial arrangement that enables one to “cash out” the community service obligation as it were, with much of that cash actually passing to the charity.)

Our Head of Compliance had become aware of the cash-out alternative, and wanted to take advantage of it. I was able to arrange that quickly, but after he left my office, I reviewed the situation.

A key responsibility of our Head of Compliance is to provide assurance to our board about our corporate governance and compliance with legislation. His ability to do so is proof positive of a complete lack of awareness of what is going on around him, and if he has become aware of my little program it is altogether too well known.

As some would regard my program as “arguably not a good fit with our corporate value set in all contexts” (which is about as bad as things can be in modern banking) it appears that the time has come for a good thing to end.

Now my charming but demanding editor sent me an electronic memo reminding me that my articles are meant to be instructive for entrepreneurs. I am unsure whether entrepreneurs have Heads of Compliance, so I will provide an instructive summary in the alternative, as follows.

If you are able to arrange a voice recording of your Head of Compliance seeking to cheat his involvement in the community participation program, supported by a photocopy of a genuine signature on a bogus attendance sheet, you are in a good position – unless he works for you, in which case you have an outcome that is arguably not a good fit in all contexts.


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