In the compliance world is quite common hearing or reading the sentence ‘tone form the top’, indicating an internal set of rules of what can of cannot be done.
Frankly, I believe it is meaningless as the risk is keeping that commitment just on the paper.
Establishing an effective compliance program is difficult as corporate culture needs to enforce it and corporate culture is set by means of the example from the C-Suite .
Saying something and being consistent are different things, therefore, executives need to actually show their genuine commitment throughout their organization. Middle management, being the trait d’union to the rest of the company, is essential to pursue this goal.
A few examples of what to do are:
- Executives must take responsibility to train middle managers and having an ‘open door’ should any issue arise,
- Managers should train workforce under their direct supervision on regular basis,
- Adherence to the internal Code of Conduct should be part of the Managers’ evaluation.
One last point that I would like to bring to your kind attention; we are living difficult times and some compliance matters such as AML may have other implications such as terrorist financing.
I am sure you do not want to be the Financial Institution in which terrorists were keeping their accounts, so, please, allow your compliance officers to take their time to complete a Customer Due Diligence, make them use all their skills.
If they think something is not right, probably it is.