Time for ‘Bad Banker Registry’?


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Banking scandals implicate culture

If the Wells Fargo debacle has you cringing this month, you may be among those wondering whether it’s finally time for a ‘Bad Banker Registry.’

William Dudley, president of the Federal Reserve Bank of New York, said this week that he favors creating such a registry—the purpose of which would be to identify individuals with what the Wall Street Journal story described as “questionable values.”

Dudley noted in the Journal that regulations can’t keep pace with the reality of some of the behaviors occurring in the industry. Others noted the negative impact on ethical culture brought on by compensation packages laden with bonus opportunities, a problem particularly noticeable in U.S. firms.

Dudley, who hosted a one-day conference for fellow executives and industry leaders, acknowledged that current U.S. law related to employee rights would not allow such a registry but that new legislation should be considered given the magnitude of the problem and the inability of the industry and regulators to correct the problem of culture.

Jon Picoult, writing for the New York Times, tackled this question of culture and the risks of the ‘do as a I say and not as I do’ mentality: “But how can a toxic culture develop in a way that is diametrically opposed to everything leaders supposedly say and stand for? The answer lies in a variation on the classic “Do as I say, not as I do” admonition. Employees will get their cultural cues not from what management says but from what it signals.Those signals are embedded throughout the workplace. They can appear in overt ways, such as how compensation and recognition are done. Or they can emerge in subtler ways, as in which metrics managers obsess over, what questions they pepper employees with and how they react to dissenting opinions.”

Best AML tech turns intent into daily practice

This issue of culture has been especially interesting to AML Partners because we have built so many ethics-friendly features into SURETY Eco, our AML software ecosystem. In short, SURETY Eco provides a blank-slate canvas onto which users may transfer the operational nuts and bolts of their entire risk-based approach. This includes workflows, users and their precise permissions, risk models, PEP registries, collection questions, documents, an email-reminder system, a full archive of who did what and when, and so much more.

These features and extraordinary configurability are boons to institutions seeking to formalize and operationalize their good intentions and smart planning regarding AML Compliance. SURETY Eco in essence helps a CCO transform stated intentions about AML Compliance into a fully operational digitized ecosystem for Core Compliance.

“Intentions” is the key word here—institutional intentionality in adhering to a true risk-based approach, intentionality in determining the complex risk modeling that is explicitly suited to one’s book of business, intentionality in assigning accountability for AML Compliance among people and departments, and intentionality in selecting an AML software solution that accommodates your every intention and then archives the who/what/where/when of every action taken.

The right AML software solution should be an integral part of a financial institution’s ongoing conversations about culture and tone from the top. In addition to supporting all the critically important day-to-day work of core AML Compliance, an AML software solution like SURETY Eco can also be your Intentionality Toolkit—where your words and intentions transform into concrete, archived actions. That kind of approach would obviate the need for a “Bad Banker Registry,” and that would be a win for everyone.


SURETY Eco: AML Compliance for An Evolving World

Does your AML Compliance software solution adapt as quickly as the AML Compliance environment changes around you? SURETY Eco, our AML Compliance Ecosystem, is in-house configurable for virtually every change in AML Compliance requirements. Our  “Comply on the Fly” technology can transform the efficiency and effectiveness of your AML/CTF Compliance. To learn about SURETY Eco and its fully integrated CDD/KYC, transaction monitoring with optional 314a, and sanctions screening capabilities, call us today. We will show you how SURETY Eco adapts completely to your unique risk-based approach.