Within the organisation, you will have the full range. The vulnerable will be targeted with bribery, blackmail or bed. The criminal will be invited to join the venture for a stake in its outcome. The malicious will do it because they didn’t get a promotion. The careless and the thick…. Well, how can you guard against that?

Your training needs to be a sales pitch. When you decided to put in place TQM systems, you had to sell it as a benefit. And, broadly, you were probably successful. You have to adopt the same type of approach for a compliance system. The training is not about the law nor even about money laundering. The training is about keeping yourself and your colleagues out of gaol. You will not sell the culture change which is required by trying to impose a series of rules, forms and sanctions. You will have to sell three things:
1. if you foul up, you will face prison for a very long time;
2. if you foul up, the team you work with will also run that risk;
3. if you foul up, you may, in some circumstances, find that the Court will order that your possessions are forfeit.

This might be one way of selling them:

"The bank will do everything it can to help you, but it cannot do your job for you. Your job has responsibilities attached and one of them is to comply with the law. But, if you break the law because you rejected the bank’s help, the bank will not be able to support your defence. If you don’t follow the systems the bank has put in place to help you stay within the law, you will of course have rejected the bank’s help.

So, the bank has worked with experts to design a system which is intended to keep everyone within the law unless they deliberately go outside the system. We think this is so important to everyone in the whole bank that everyone has to follow it for the benefit of everyone else.

"The bank has decided that everyone is entitled to the peace of mind that they will not face prosecution as a result of any member of staff refusing to follow the system and so, for the protection of everyone, it has decided that failure to follow the compliance system will be regarded as gross misconduct within the terms of the bank’s standard terms of employment. This may mean instant dismissal."

The concept has to be one of “not letting the side down”. Remember that those who are coerced will have someone else telling them that they must not let that side down.

Your threat is merely financial - “disobey and you’re fired.” Criminals also have the threat of firing - houses, cars, guns. You cannot compete with that type of threat unless you give your staff a level of commitment which is strong enough for them to deal with coercion.