How can financial institutions ensure their employees behave properly? They can spend a fortune on monitoring behaviour, rewarding the good and punishing the bad. Yet there is a limit to how much a compliance department can do.

The fact is that the best compliance officers are actually an employee’s ordinary colleagues. Few instances of bad or risky behaviour are done without someone else knowing and if more of those eyewitnesses came forward it would be a more effective deterrent than ever higher fines. If you don’t think you will be caught, the level of punishment is irrelevant.