This stands alongside various other efforts for training and standard-setting, including those by AIF, ICLIF, SIDC, FIDE Forum, PPKM and FSPB. I wish to take this opportunity to specifically commend the AIF and FSPB for their initiatives, including today’s event. These draw the much needed attention by the industry to this important subject. The system of values affecting behaviour does not only depend on the sector-wide legal and regulatory frameworks and the vibrancy of the professional community. Also, of crucial importance, is the role of the board and senior management in each organisation. As has been often repeated, these leaders set the tone from the top. This is established through official decisions and formal statements, including the corporate values and various codes of conduct. However, their role goes much further than that. More than their words, the board and senior management determine the prevailing values of the organisational ecosystem through their attitudes, actions and decisions – especially those relating to professionalism and integrity. Do they give the impression that the ends always justify the means? How vigorously do they question sudden surges in a business unit’s profitability? Are they willing to overlook ethically questionable actions so long as the firm is technically within the bounds of the law? How do they react to ethical failures and misconduct? How does compromising the policies of the organisation affect bonuses and promotion? Apart from the board and senior management, the system affecting each organisation is also determined by the shareholders.
I think we’ve been clear in our expectations around AML/BSA: •  That AML/BSA needs to be managed on an enterprise-wide basis;  •  That AML/BSA needs to be a high priority for the board of directors, senior management and line management;  •  That the message on compliance needs to be carried down well into the organization, so that those who are on the front lines making daily decisions understand the importance of compliance and the consequences for failing to meet the requirements; and  •  That AML/BSA shouldn’t be treated as a static exercise – standards and best practices evolve and you are required to keep up with and adhere to the latest requirements. As I know you are also aware, we are seeing keen competition for talent/resources in this area. While we recognize that it may be difficult to identify and retain talent, having a solid recruiting strategy and ongoing training in place, as I mentioned earlier, are important components to addressing the problem. You might wonder why this topic remains on my list – and it’s because in spite of the heavy public attention on the matter, including a range of public enforcement actions, it remains a work in progress for many firms. And, for firms that haven’t yet been faced with MRAs or a public enforcement action, I worry about complacency. So, I raise it again because it seems that another warning shot is warranted. 2.