An arrow straight to the heart

The Financial Services Authority may be going the way of all regulators (well, some) come April 2013 but it cannot hang up its quiver of Arrow supervisory visits [1] for the last time without letting fly one more at Radleys, the bank where Edward Jones is MLRO. He would have liked more than three working days to prepare but such is life in AML compliance. Sue Grossey monitors his team’s rising adrenalin.

Susan Grossey may be contacted on +44 (0)1223 563636, susan@thinkingaboutcrime.com, www.thinkingaboutcrime.com

Edward Jones, MLRO, received many emails every day. Some made him laugh, some made him sigh, some made him cross – but few filled him with such despondency as this one. It was from the bank’s director of compliance, and this fact alone was enough to make Edward shake his head. William Winterbourne – or “Weewee”, as his irreverent underlings were already calling him – was not a man of compliance courage or conviction. He had made the mistake of being on the slopes of St Moritz when an emergency board meeting was held to appoint a new director of compliance, and to say that he was a reluctant poacher turned gamekeeper was an understatement. He tried to avoid making any compliance statements at all, seeing the whole endeavour as an enormous waste of time, but occasionally events conspired against him and forced him to take action. Today was such a day, and the email heading said it all: “FSA visit imminent”. Edward clicked to open it.