Over 30 years ago it was Bank of Credit and Commerce International (BCCI). Regulatory tunnel vision, corporate giant, false accounting and bad auditing, money laundering and terrorist financing, transactions made across the globe, MI5 and CIA involvement, cover up’s and administrative failings.

Lawyers for the liquidator of BCCI filed a lawsuit against the Bank of England who gave them their licence in 1980, claiming that over a considerable period of time they deliberately ran away from seeking to find out sufficient information about BCCI. A 1992 report by Lord Bingham, at the time Britain's most senior judge, criticised the Bank of England for not spotting BCCI's criminal behaviour earlier, but blamed poor communication and procedures rather than deliberate negligence.

3 years ago it was Wirecard. Regulatory tunnel vision, corporate giant, false accounting and bad auditing, money laundering and terrorist financing, transactions made across the globe, Russian spies and Libyan militias….. You get the picture. Nothing changes.

The German financial regulators BaFin, initially turned their attention to those who criticised Wirecard, now they themselves have been the subject of allegations that they protected Wirecard instead of conducting proper investigations.

Both companies were corrupt and systemically falsified their records and yet auditors and financial regulatory bodies failed to act in time even in the face of fraud and deceit. Their tunnel vision led them to answers, but it led them to the wrong answers because they made assumptions and their decisions based on those assumptions were wrong.

In the financial crime world we look to typologies and lessons learnt, this is the theme of my writings and why I look backwards to go forwards. It is the financial misdeeds, improper actions and devastating consequences of the past that can help to educate us, not to ensure it doesn’t happen again, but to understand the importance of case reviews. These are not re-investigations but hopefully, an objective and fair evaluation of past events that seek to identify opportunities that were missed due to cognitive bias or questions that were not asked or, in some cases, why the answers to questions were the equivalent to covert abusive tactics.

Des Hellicar-Bowman is Senior Executive with over twenty years' experience at Board level within the payments industry. Well versed in regulatory and risk requirements. Experienced in compliance and MLRO roles and a knowledgeable individual within industry, regulatory and card scheme circles.