I travel to financial institutions throughout the country all year long. I am sometimes asked if I see certain compliance problems over and over. One possible approach to answering this question is to say that BSA, UDAAP and ECOA/Fair Lending issues are what I see happen most frequently. But, the deeper way of answering this question is to say that the top compliance issue I see is apathy.
Zeroing in on the causal factor of any compliance violation is a critical exercise for compliance personnel/specialists. A failure to properly source the cause of the violation will likely mean that the course of corrective action is ineffective and/or inefficient at best and, at worse, a potential worsening of the problem.
Our experience in causal factor analysis would identify apathy as the cause of most violations. Most violations stem from an inherent lack of concern or interest. They simply don’t see the importance. Second to that would be ignorance, but that typically also stems from apathy.
The counter to apathy is a combination of awareness or knowledge combined with risk appreciation. There is no question that apathy towards a higher-risk BSA situation facing the financial institution can be disastrous, but even lower-risk areas or institutions must have some interest in their efforts towards these subjects.
The smart institution isn’t necessarily promoting compliance above all else, but it is focused on risk-appropriate efforts based on an awareness of existing and emerging risk factors in compliance (a good place to start each day is 5 minutes at NBHotList.com). When diligence is given to awareness, my experience is that common violations are significantly reduced and/or eliminated.