August 11, 2022

Sign, Sign, Everywhere A Sign

Blockin’ out the scenery, breakin’ my mind. Do this, don’t do that – Can’t you read the sign?

Okay, I am totally dating myself by referencing a song from the early 1970s and although I was just a kid then, those lyrics always stuck in my mind – especially the part “Can’t you read the sign?” In this song, the signs are restrictive, and many signs still are – “No Trespassing”; “Restricted Area”; “Private Property”, etc. But signs are also meant to keep us safe – to keep us from hurting ourselves - “Danger – High Water Ahead”; “Caution – Wet Floor”; “Watch Your Step”, etc.

The thing is not all signs are flashing or smack us directly in the face. Some are more subtle, but they are still there, and it is up to us to determine the lessons we need to learn. For example, on a routine basis, the Office of Foreign Assets Control (OFAC), the Financial Crimes Enforcement Network (FinCEN), and the FFIEC regulatory agencies (FDIC, OCC, FRB, NCUA, and CFPB) all publish notices of enforcement actions imposed against financial institutions or individuals/entities for violations of sanctions, requirements of the BSA, safe and sound banking practices, or consumer protection laws. It is just smart to learn from the mistakes others make – so taking time to read these notices and assessing if this could happen to your institution is just the rational thing to do. Regulatory agencies don’t publish notices for their own benefit, they publish for yours. These notices are billboard-sized signs that you should act on to ensure your institution is not headed down a similar path and your examiner expects you to read and learn from them

So, take heed before “do this, don’t do that – Can’t you read the sign?” turns into “Here’s your sign.” (For those who want to relive the 1970s!)

Authored by: Joann Lang, CIA, CAMS, CCBP

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