20170830 The Commonwealth Bank of Australia – sickness or symptom?

This is a highly material point: it has long been said that an expert is someone who knows even a little more than you. And in the highly (and unnecessarily) complex world of money laundering, etc. compliance and risk management as boards know little, even those who toss around the current buzzwords seem to be expert.

As regulators around the world look at Commonwealth’s systems and controls, the question of competence and capability of “certificated” or “certified” money laundering staff and officers must become a live issue.

The certification companies have now reached such a high-level of market penetration that regulators have no choice, if they do their jobs properly but to ask why, if the certifications are seen as a measure of competence and capability, are there so many failures? Are those certifications (they are not “qualifications” for their is no profession to qualify for) fit for purpose?

We are now past the excitement point of the Commonwealth news cycle. We are now into the grind where specialist media will pick up on the progress of investigations and general media will pick up on court, etc. reports or stage-managed “perp-walks” for officers of US branches, if they can find anything to justify attacking another foreign bank.

In two or three years, we will see some regulatory action. We will almost certainly see no individual in the criminal court dock. Similarly, we will almost certainly see no significant sanction, other than a monetary penalty, to bribe authorities not to commence or continue criminal proceedings.

That’s not a pity, it’s a shame, in the true sense of the word. The world will keep on turning and nothing will change. The media will move on to the next big thing which, in Australia, is usually a minor political scandal which results in the prime minister being replaced with someone equally ineffectual.

Outside Australia, the financial world will look and say “oh, well, it’s just a little local bank on the other side of the world. Nothing to see here.”

And when that happens, there is only one group to blame: regulators who don’t have the courage or competence to ensure that regulated businesses do the best job possible and police sensible regulations, rather than constantly revise and add to regulations that are already so bloated and complex that they are not fit for purpose.


© 2016 Nigel Morris-Cotterill
All rights reserved.


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