It erodes what some commentators call the “culture of compliance”, and it tends to foster an employee population that will be inclined to look for loopholes, to place toes on the edge of the permissible, or even to turn a blind eye to a black letter compliance rule. And, the organization’s compliance staff will also suffer from a stifled motivation and the absence of any meaningful authority – it relegates that staff to a bunch of box checkers, rather than people working toward a safer and better world. Is it a surprise then that foreign institutions have problems with sanctions compliance and U.S. institutions do not? I do not excuse this in any way, but I do understand it. Let us now turn to tax evasion. On May 19, Credit Suisse pled guilty to conspiring to help certain Americans evade their tax obligations to the Federal government. Credit Suisse agreed to pay a fine of $ billion. Like the criminal disposition concerning BNPP, this was headline news. Credit Suisse had well developed compliance rules addressing what relationship managers could and could not do when travelling into, and through, the United States. But those compliance rules, while cogent, were largely ignored by certain Credit Suisse personnel. Why is that? Here, again, I believe that the answer lies in the organizational value system. Credit Suisse was not alone in aiding customers to evade taxes. UBS had similar problems although it escaped without a plea to a Federal felony.
Mobile banking will lead to increased outreach, increased efficiency and productivity as well as increased returns for businesses. Let me once again assure you, Mr. Chairman that, the Bank of Zambia is committed to providing an enabling environment through appropriate regulation for banks and financial businesses that wish to promote financial inclusion. We appreciate the Mobile Banking initiative by Celpay Zambia Limited and look forward to greater investment in financial inclusion in our beloved country. I thank you. BIS Review 111/2009  3