Nigel's Eyes

20221214 No slow news days if you are in financial crime risk and compliance.

#Tuesdays always used to be slow #news days.

Tuesdays were the day that #direct #marketers knew was the best day for that #brochure or #unsolicited #sales #pitch to hit desks. Tuesdays were the day that #telesales people knew they were least likely to be brushed off. Tuesdays were the day that people had time to talk over #coffee. Tuesdays were the day no one cared if you were a few minutes late or left a few minutes early. Tuesdays were the days that city centre #bars expected a slightly longer - and more profitable - lunch "rush" because people didn't rush.

Tuesdays were the day you'd read to the end of this post.

But that doesn't work any longer because, today, there are no days: free or nearly so e-mail and telephone calls have removed all barriers to a bombardment of executives with marketing all day, every day. Round-the-clock access through an array of pocket and back-pack devices means that office hours are, for many, a myth.

It's not just the hassle from marketing people. Businesses now run 24 hours a day, 365 days a year so they must be staffed for those hours. Customers expect that if the electronic door is open for on-line transactions, that there will be a human to answer their questions promptly.

A few hundred metres from my living room window is the head office of a major bank: the lights are on on the compliance floor all day and night, every day and night. Ditto other banks.

24 hour business means 24 hour risk and compliance: this cannot be delegated to an automated system that produces exception reports to be reviewed the next time someone is in the office.

Before I specialised in #financialcrimeriskandcompliance, clients in my #law firm included some large #financialinstitutions. There were #bank managers, a man (usually) who sat behind a desk and who had both business and social interaction with his customers. He knew who they were, he knew their families and he knew their financial situation. He literally, knew his customers. Bank staff knew customers by name. They could tell if something was out of the ordinary and not only for financial crime risk.

Every morning, the manager would receive a binder full of printouts the first page of which would be #exceptionreports of #accounts that were overdrawn as of close of business the previous day. If #cheques arrived for clearing, he would make a decision whether to allow an unauthorised overdraft or to return the cheque unpaid.

Days were structured. #Weekends were structured. #Holidays were structured. When #branches were closed, the business was closed.

Today, risk and compliance teams are under extraordinary stresses, from internal demands through demands from regulators to demands from customers.

Someone, somewhere has to say "enough". Exhausted and - frankly - fed up people do not do their best work. Risk, especially, is a matter of judgement. We know that people make poor judgements when their decision-making capacity is impaired.

We need to find a better way to manage the job.


Keep an eye on for news of the forthcoming Online Forum on Workplace Stress in Financial Crime Risk and Compliance.