It’s only foolish consistency that’s the hobgoblin of little minds. Emerson, Self-Reliance.

The government requires financial institutions  to file suspicious activity reports.  So do the financial regulators in the UK. 1.3 million such reports were filed in the US in 2008. You file more than 150,000 of them a year.

What if you file one in the UK, a month before Bernie Madoff’s arrest, based on conduct in the UK, but not in New York?  Five years later, you may face having to settle a case for millions or billions.

Is it a question of consistency?  Or would such a filing have resulted in an earlier arrest of Madoff? Or is it just further bullying of J.P. Morgan by the DOJ?

“J.P. Morgan Is in Talks With U.S. Over Madoff,” December 7, 2013 B1

In a large, multi-national operation, how do you make sure you disclose what someone in your organization knows? How do you know what you know? Do your processes require the filer in the UK to notify all the other offices, so that they can meet their filing requirements? 150,000 times a year?


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Filed under Business Case, Controls, Information, Legal, Operations, Requirements, Risk

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