Too much content control

Is it possible to control your content too much?

To avoid violations of the US trade sanctions against a bunch of bad actors, companies often train people to be on the watch for “hot words,” words that indicate you may be about to engage in prohibited conduct including, for example, money laundering.  But what if some bright spark came up with the idea of removing those “hot words” from company correspondence, but otherwise continuing with the prohibited conduct?

That appears to have happened to Royal Bank of Scotland. “RBS to Pay Penalty Over U.S. Sanctions,” Wall Street Journal, December 12, 2013 C3 http://on.wsj.com/Jj00Hz  Cost: $100 million in fines.  And terminations for former head of regional banking services and the former head of the money-laundering compliance unit.  Still, no one went to jail.

So, do compliance programs teach people too much?  Is knowledge a dangerous thing?

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Filed under Business Case, Compliance, Content, Controls, Governance, Information, Internal controls, Legal, Requirements, Risk

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