Humans have a remarkable ability to get used to things. For example, on a trip to Yellowstone National Park several years ago, I saw a group of people excitedly pointing to something off in the distance. They had cameras out and were acting as if they were seeing Sasquatch. However, when I got close enough to see what they saw, I realized it was only a few mule deer. The people admiring the deer, it turned out, were from a large urban city outside of the United States, and had never seen mule deer before. What was commonplace to me, as a local of this area, was extraordinary to them.
This ability to adapt and grow accustomed to things and situations can be both a good thing and a bad thing. When we become so used to something, it’s easy to pay less and less attention to it, and we start to just go through the motions. With Bank Secrecy Act compliance, it is all too easy to simply go through the motions, especially when it comes to collecting information about potential new accounts. It’s tempting to become careless in collecting information due to the repetitive nature of the process unless we keep the end purpose in mind: catching suspicious activity. Because of this, it’s a good idea for compliance personnel to take a step back every now and then to make sure BSA compliance isn’t just a part of the daily routine.
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