Ripples into Tsunamis

Working in the finance industry, there is very heavy regulation. We are in the business of making sure money is secure. Granted, most of it makes sense, but as an employee, it is my duty to go through compliance training every year (Shut up, Lenny. I can be compliant when I want to be!). Last week was a biggie because my department had to complete BSA Compliance Training.

A short rundown: BSA stands for Bank Secrecy Act. Basically, the Office of the Comptroller of the Currency (a.k.a. the OCC, based with the U.S. Treasury Department) requires all banking institutions to monitor and report suspicious activities. This includes a group of laws for Anti-Money Laundering (AML), Suspicious Activity Reports (SARS), and the US Patriot Act. Going off for an hour and a half about rules and regulations normally really blows. However, BSA is one of my favorite classes to take every year.

Why? There’s nothing like real life case studies in which you see BSA penalties in action. According to our BSA Officer/Trainer, “Penalties can be imposed on Board members, Directors and Officers of the Bank and employees.” Check out what I learned about “Good Banks Gone Bad:”

1. AmSouth Bank fined to the tune of $50 million in penalties for AML deficiencies.

2. Riggs Bank was wiped off the map and dinged for $25 million in fines for CTR (Currency Transaction Reporting) violations and exhibiting “willful blindness.” Willful blindness means that they were informed by the OCC Auditor what was wrong, but they didn’t fall into compliance.

3. ABN AMRO hit with $80 million for failure to report suspicious activities, provide appropriate BSA training, and inadequate staffing to support BSA.

The kicker in all these cases? The information is PUBLIC KNOWLEDGE. Our BSA Officer can pull a report that says WHO exactly has to pay, HOW much they have to pay, and WHY they have to pay. After class, I read through some of the case scenarios given to us and actually did a little internet research. With each story, I kept coming back to one thought. All of these sad endings were the result of ONE person making a decision and starting a ripple effect. And because people ignored it…the ripple just grew. By the time the government got a hold of them, they were dealing with a full on tsunami and were drowning in government violations. Each person in the ripple probably had the opportunity to stop what was going on, but they got swallowed up by the wave when they ignored it.

We can sit back and say these banking institutions deserved it. You can watch TV and say the Kenneth Lay/ENRON debacle just shows how corrupt our corporate society is. But when you take the “it starts with a ripple” theory and apply it to something smaller and more human – it really becomes everyone’s problem.

Unfortunately, we live in a finger pointing society. We never really think that “one small” action can have a big effect on the greater scheme of things. Our fallacy is that we think it doesn’t matter because it doesn’t make a big splash in the media like the corporate hooligans do. Little indiscretions are no big deal…because a majority of us think “no one’s going to care” and “everyone else does it!”

When things go wrong, we tend to dig just far enough. Violence among youth? It’s not the fact that a lot of kids are missing actual parenting – it’s gotta be the violent video games that their parents buy them. The homeless and unemployed? Can’t be that we’re not putting enough money into education or self-improvement – it’s because they’re lazy. The divorce rate being up? It’s not because we don’t talk about the “hard part” about marriage – it’s because marriage is a sham institution.

When are we actually going to start taking blame for our own actions? As humans, we should be able to step up and say “my bad” and move on. Imagine how much of the little crappy troubles in our world would just disappear with a little self-responsibility.

Stop blaming your parents for how screwed up you are as an adult. Stop blaming your boss for the fact you haven’t moved up the corporate ladder. Stop blaming McDonald’s for the fact that our kids are more obese than ever. Choice, people. We have choices. You know how Denis Leary is fond of saying, “Shut the fuck up…NEXT?” It’s time we went on to what’s NEXT.

It’s not the easiest thing in the world to do. It hurts to know you were wrong. But its so worth it in the end. We’ll stumble on this path, but hey…it’s a rocky one. I for one plan on running up the hill at full blast, even if it means I stumble. It’s better than being swallowed up by the tsunami, that’s for sure. None of us can really afford for that to happen.