A little while ago I was giving a training session and used an analogy that the people attending found useful and amusing. And, being both vain and generous, I thought I would share it in case it helps with your training. I was trying to explain why people in compliance often have difficulty persuading their colleagues in client-facing roles (in short, the sales people) to complete the required AML checks to the specified standard within the necessary timeframe. And then I mentioned the woolly mammoth. Wavy lines, if you will, as we drift back to the Palaeolithic era. Humans have gathered into small communities for safety and companionship, and they are what we would recognise from the movies as cavemen (although I’m not convinced any of them wore a bikini and bootees like Raquel Welch).
Each day a small group leaves the safety of the cave and goes in hunt of the woolly mammoth. This is a valuable beast, as it will provide the whole community with food from its flesh, clothing from its skin and fuel from the leftovers. Waiting back at the cave are the other cavepeople, discussing what should be done with any mammoth they get: how to check it for eating suitability (you don’t want to eat anything maggoty), how much to scoff straight away and how much to store for later, which are the most urgent items of clothing to be made, and so on. And hurrah! There is a kill, and the hunters drag the mammoth back to the cave. “Join us,” say the waiting people to the hunters, “while we process this beast – you can help us decide how many chops to make and which bit of skin will make the best maxi dress for Raquel.” The hunters yawn and frown and shake their heads. “That’s way too boring,” they reply. “That’s your department, doing the checks. We’re going for a shower and then we’re off on the hunt again. We think we saw an even bigger mammoth in the next valley.”
Now I know that any analogy can be stretched too far, but nothing I have seen in more than two decades of working with compliance teams and sales people has changed my mind on this one. I don’t know what makes you one or the other – whether it’s nature or nurture – but I do know that they find it hard to understand each other, and they rarely switch sides. And – this is crucial – the overwhelming majority of firms are run by mammoth hunters rather than mammoth processors. In other words, CEOs almost invariably come from the sales side rather than the compliance team. And an ongoing challenge for any MLRO is to find the right language with which to communicate with a sales-driven CEO and Board: sales is all about numbers, and risk-based compliance is very much not.
Somewhere at the back of my mind I’ve found Deal and Kennedy’s model of organisational culture. They characterise culture as a two-by-two matrix, with axes of risk appetite, and speed of feedback. (It’s nicely explained here: https://www.open.edu/openlearn/money-business/leadership-management/management-perspective-and-practice/content-section-3.5.1)
Your mammoth-hunting salespeople will be high-risk quick-feedback – D&K’s “tough-guy macho culture”. Meanwhile your mammoth processors back at base are probably low-risk slow-feedback – D&K’s “process culture”.
I’m not sure what you’d do to fix the culture mismatch. Perhaps Compliance could start making instant all-or-nothing decisions on the initial client data collected by sales. “Don’t like the look of this mammoth – get it out of here.”
That’s so interesting, Cartebien – thank you for sharing it. I had not heard of this model, and yes, it’s all about culture mismatch, isn’t it? A really tricky nut to crack.