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by wcunning 1223 days ago
The best thing I've read on this topic is from Matt Levine at Bloomberg, restated in his newsletter on Wednesday: "In general, the chief compliance officer at any company has a dial in front of her that she can turn to get More Crime or Less Crime, and at a normal company — a bank, for instance — her job consists of (1) turning it most of the way toward Less Crime, but (2) not all the way, and (3) acting very contrite when politicians and regulators yell at her about the residual crime. “We have a zero-tolerance policy for crime,” she will say, and almost mean."
2 comments

I also think this is a very important mental model for the job to be done of Compliance departments, and I think I cited it in the KYC piece.