Culture, not Controls

In an environment chock full of regulatory change, enforcement notices are well-worn reading material.

Compliance and risk teams pore through enforcement notices to see what lessons they can apply to their own businesses, seeking to offset similar criticism when (not if!) they find themselves before the regulator.

Enforcement notices often talk about controls failures:

• Did your customer screening go wrong?
• Did you forget to test something in the background for a while?
• Was there a key person dependency that resulted in a problem slipping through the cracks?

Failures like these are ubiquitous, and nobody working in financial crime will be surprised to see them - and if we’re being honest, they’re pretty simple to solve.

What’s harder to solve are the cultural problems that run through virtually every business in the world.

• Is the Board listening to the staff it hired? Really?
• Do people feel they can speak up? Are you sure?
• How high was attrition last year? Why?

Problems like these are chunky and complex. They need sophisticated thinking and open-minded approaches to get successful solutions in place.

Controls are the easy bit - Culture is the hard bit.

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Get the Hard Bit Right

Tackle Problems, Not People

When something goes wrong, it’s natural to try to find someone to blame— but in the long term, people might try to avoid making decisions for fear of reprisal. Instead of questioning a person on why they did something, ask why they were ever able to. What can we do to make sure that this can’t happen again? Solve the problem, not the person.

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Tell Better Stories

A lot of financial crime information can be a bit dry to the newly initiated, but financial crime is the plot of tons of bestseller thrillers. Dump the boring slide deck; ask your SMEs to offer live training with real world examples. Record an internal podcast and keep the bloopers for a Friday afternoon when everyone needs a lift. A good story, well told, will get your multi-disciplinary teams on side for the journey.

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Implement Radical Honesty

Your people are in the trenches and they know the problems better than you do. They’re already talking about those issues and they want you to listen! Push back against the urge to be defensive and ask them to give you a firm talking to— and then implement their ideas. They get autonomy, you get fresh thinking. Win-win.

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Diversity People = Diverse Thinking

People bring insights from previous experience, which means a diverse team offers you a chance to see problems in entirely new ways and tackle them with integrity alongside good learning. Find out where your staff have worked and lived. What makes them tick? How could that help you solve problems in new ways?

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Invest in Skills for Success

After you’ve had a long hard look at the world you’re working in, you might realise you need some help along the road. That’s where DCM can help. We’ll support you to get your frameworks ship-shape, your governance efficient and your remediation complete — so you can move on to delivering the big strategies within a great culture.

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If you'd like to learn more reach out to the team at info@dcmoperations.com.