Compliance Training

TMM were recently comparing notes with friends around the market (and indeed some not in the market but in other large institutions) over the pleasures of online compliance, ethics, anti-bribery and anti-money laundering training. Of course these courses are designed to pass the onus of responsibility from the company to the individual and prevent said company enduring prosecution for the actions of its employees, but the courses themselves often appear to be written by the same people that design tax returns, benefit forms or immigration documents. The clue is the way they veer wildly from mind numbing tedium that is little more than "can you manage to point the mouse where we tell you and copy theses letters" to the bizarrely perverse obscurity of which day of the week you are allowed to accept a $10, not $20, gift token from your grandmother and not declare it in a very large book kept in a safe three buildings away and in which colour pen.

The multiple choice questions that always end the "how fast can I click through this" course are also of a very predictable form. Three options are along the lines of "don't tell anyone unless it's inside information in which case leave it on the photocopier" and a fourth, the correct one, which contains the words "inform your Money Laundering Reporting Officer (MLRO) or line manager".

So bearing those prerequisites to a successful compliance assessment in mind Team Macro Man offer you their own version. As usual you have three attempts to achieve the 80% needed to attain a pass before you will be reported to compliance.

1) A man arrives in reception with a striped top on, a balaclava and leather gloves, says he has £75m he needs to deposit tom/next. He has no KYC docs, but plenty of KFC. Do you

a) Take the bargain bucket and the money
b) Take the bargain bucket only
c) Offer the Money Laundering Reporting Officer (MLRO) two pieces of chicken and a week in the KFC City branch all expenses paid.

2) As you enter your building you notice a senior member of management "slipstream" you through the security gate without using an ID card. Do you

a) Ignore it and carry on as it isn't worth the aggro.
b) Escort him back to reception and make sure he proves his identity before attempting to re-enter.
c) Rugby tackle him to the ground, then smash his forehead repeatedly into the genuine Italian marble flooring whilst whispering into his ear "This is for last year's bonus, arsehole" and screaming loudly "HELP HELP INTRUDER !!!!"

3) Ethel and Leonard Dalrymple , who normally trade their account once a year, call to say they have won €250mm on the Costa Del Sol Lottery and begin trading clips of €10mm a time on March 2013 delivery Lard futures , do you

a) Tell them it's normal for the bid /offer spread to be 20% of the cash price and deal anyway
b) Offer them a £500 a night, all expenses paid trip to Butlin's Bognor Regis holiday camp , with unlimited cava and Pringles in return for a sole new issue order.
c) Offer the MLRO a magnum of cava and a week in Marbella to let you open a safe custody account in your name.

4) You are in a nightclub whilst on a ski holiday in Zettmypantsonfeuer with friends and are approached by a svelte 22 year old blonde proffering Hedonist-A-Go-Go shares at a huge discount. A firm in which you have a controlling interest as a founding member: Do you

a) Accept the special offer and commission rebate without saying anything
b) Ask, slightly aghast, "do you know who I am?" whilst revealing your faux chamois leather thong and walk away from the deal
c) Offer the young Frau some "special advice" only available from your suite , and also partially do a) and b)
d) Report the incident to your MLRO on your return to the UK three days and three stone later

5) Your colleague Steve is shaking and sweating violently, his pupils are dilated and he has clear needle marks on his forearms. You notice him levering open the cash till and ask him if he is alright. He appears shocked by your approach and pleads with you to open the till or he's a dead man. Do you

a) Open the till for him and suggest he switches dealer to Pedro who isn't so violent.
b) Lock the door, pull out a reefer to share and tell him to just chill man, it'll all be ok.
c) Report the event to your line manager or MLRO as your colleague's behaviour is suspicious and out of character.
d) Action (c) but then ring them back amending your report as you realise that Steve's actions are actually in character as this happens most Monday mornings.

6) You have been appointed CEO for life of Hedonist-A-G-Go Plc after a long and bitter takeover battle which involved taking a poison pill to despoil your erstwhile hostile partners by over paying vastly for Wendy's Tasteful Flowers PLC (WTF). You have been approached by Appleby Inc(AI) who inform you off the record of a cancer gene being discovered in the petals of the blue Delphinium ( Bolluxia Sapphic Deum) and he knows you have a pending bid by a deranged asset stripper for WTF. Do you

a) Offload WTF as best you can to the asset stripper and pray AI s info turns out correct
b) Buy a majority stake in AI Inc asap and claim it was in house research
c) Send a huge bouquet of Blue Delphiniums to Bashar al-Assad signed "hugs from Mahmoud".
d) Report your quandary to your 23 year old Angelina Jolie lookalike MLRO.

7) Fidel Castro walks into your branch and despite his false nose, Kim Il Jun suit and Sudanese passport you have a suspicion that he is not who he appears. On checking his signature against the one you have on file you find that the "tittle" dotting the final j in Mahmoud Ahmadinejad is a full millimetre out of place. Do you

a) Ask him to have another go at the signature pointing out where the discrepancy lies
b) It's close enough, so you willing cash his cheque from from "Embargoed Oil" and make the payment to "Nukes 'R' Us".
c) You see a cross sell opportunity and introduce him to your Wealth Management department.
d) Inform your MLRO office and line manager as you have spotted a Syrian stamp in his passport,  Syria being a sanctioned country.

8) An old friend pops in to see you after a very long lunch at the City Club reeking of port and cigars and sporting classic red wine lips. In his battered brief case he has several large wads of grubby £50 notes. Swearing you to secrecy, he tells you there is about two million quid that he has been given as "Thank yous" over the years for various deals he did with friendly overseas defence ministries. Do you

a) Wheel him back to the City Club and blow as much of the contents of the case as you can on the oldest vintages on the list.
b) Suggest he invest it in a Jersey based OEIC because they don't check too carefully.
c) Remind him that you are an institutional Fund Manager and that effectively you don't get out of bed for less than £100million these days.
d) Ask your MLRO what is the most effective wash cycle for dirty £50 notes.

9) You are abducted unexpectedly from a strip club in Mayfair by Martians who inform you that in fact Rasputin/Beria/Stalin/Hitler/Mussolini/Pol Pot /Genghis Khan and Piers Morgan were all in fact closet bankers . You had just invested heavily in a charity, Bankers Easily Lie Lots, Endeavour Never Fails (BELL END) and had persuaded Great Ormond Street Hospital( GOSH) to invest all their monies with you before this was made available to the rest of the Human Race. Do you

a) Let GOSH go ahead anyway and hope that no one believes your story about the Martian Abduction was correct.
b) Persuade their leader, Vince Cable , that backing BELL END would be unwise as all the wrong 'uns in the known universe have always been bankers.
c) Over supper with the 22 year old ex Miss World MLRO let slip that you have a story unlike any before but that no one would believe you and did she have any contacts at The Daily Mail who might be able to help give the story some real clout
d) Ask for your LIBOR rate to be artificially ramped for sufficiently long enough to get away the option exposure on your Cliff Richard Ain't Perfect (CRAP) EBT

10) You are fiddling with the screen on your smartphone trying to text the details of the next M+A deal to your mates but accidentally switch on the camera mode as your other hand is opening the door to the stationary cupboard. On entry you trip over some discarded clothing which causes you to hit the shutter button. The flash in the darkened cupboard temporarily blinds you so you stumble back out and close the door. Back at your desk you realise that the resulting photo depicts your MLRO and line manager in a very compromising position. Do you

a) Delete the photograph as it is in clear contravention of your institution's obscene publication rules.
b) Report it to your MLRO and line manager.
c) Suggest a payrise and blind eye policy towards your future conduct would be a good idea.
d) Post it on a social networking site.
e) Suggest a threesome.


Please now complete the following survey 

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Finally, to complete the course, please sign the following declaration-

"I agree that should anything occur to encumber this institution with either reputational or financial costs due to lack of senior management oversight or failing policy, I will take sole responsibility and will willing be banged up for 20 years and used as the scapegoat leaving said senior management to continue with their self-aggrandisement".