On The Other Hand…
For many of the ABA/ABA Anti Money Laundering Conferences, Rick Small, formerly from the Federal Reserve Board of Governors and now Citigroup's Global AML Director, presented a good natured "TopTen" list - the most memorable of which was about the Know Your Customer program, which he co-authored. This year he again offered a humorous take on regulatory oversight:
The Top Ten Things You NEVER Want to Hear From Your Regulator!
10. Don't worry - the penalty won't be that bad.
9. Have you thought of a career other than banking?
8. Ombudsman - "Go ahead - Make my day!"
7. You don't mind if the Wall Street Journal watches us examine you, do you?
6. Let's see, we hit $25 million, then $50 million, anybody for $100 million?
5. You think the regulation means what?!
4. When I open my eyes there better be more SARs.
3. Safe harbor, my ass!
2. Don't worry, we're only conducting this full scope, horizontal and vertical, multi-examiner review to "encourage compliance."
1. I'm sorry. I did attend the ABA/ABA Seminar, but I missed Mr. Fox's speech.
Copyright © 2004 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 14, No. 9, 11/04
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