We’ve all taken compliance training that does nothing to change our behaviors at the teller line, banker desk, or underwriting cubicle. We can all answer the appropriate questions on a knowledge check for our required annual compliance training:
1. What year was the Bank Secrecy Act enacted?
2. Which of the following items are required for Patriot Act Compliance?
3. True or false: A customer deposits $9,567.13 in cash on a Tuesday afternoon. A CTR is required.
We could go on and on, but I want you to continue reading this blog post, so I’ll spare you. Being able to regurgitate facts about compliance regulations will not change your financial institution’s behavior. In fact, the regulations do not require your team members to know the year a regulation was enacted. Unfortunately, our compliance training is chock-full of content and knowledge checks around these mundane compliance facts.
If learning and development teams are tasked with influencing behavior change within organizations, they should accomplish it by appealing to team member’s emotions. Humans are emotional creatures. Knowing the date AML regulations were enacted do not pull on team members’ heart strings. But personalizing the ramifications of not performing the behaviors that AML requires does. This was a strategy implemented in a few of my positions throughout my career to drive team member engagement.
Consider this story:
On Tuesday afternoon a middle-aged man approached the teller window with a stack of $100 bills and other mixed bills. The amount totaled $9,560. He asked the teller to apply this cash toward his business line of credit, which she did. The next day the same man came into the bank and asked to withdraw $10,000 from his line of credit. The teller complied and made the check payable to him. He then cashed the check at another financial institution to pay a “contractor,” who was the leader of a small human trafficking ring in your home town.
What should the teller have done?
A) Complete a CTR (a currency transaction report, which is required for cash deposits or withdrawals of -+/- $10,000.01).
B) Complete the transaction as requested.
C) File an SAR (suspicious activity report).
D) Both C and B.
The answer is D. Although the customer has ill intent, the transaction does not merit a CTR because it’s below the $10,000.01 amount. The transaction, though, is suspicious and should be reported. The focus of this question is personal to the teller. It shows that what they do could have consequences that are less than desirable. Knowing the date the AML regs came into existence does none of this.
Personalizing regulations and effectively communicating to team members the ramifications of their decisions is much more effective in enforcing behavioral change than simply regurgitating facts about them. A friend recently introduced me to Peter Moreville’s User Experience (UX) Honeycomb that gained popularity in the web design space but is now gaining traction in learning design. Just like websites should be useful, valuable, and desirable, so should compliance training.
How can we make our training desirable? Personalizing compliance training drives team member engagement by leveraging real world stories of how perpetrators use money laundering, privacy violations, and fraud to do evil in the world. That is much more enjoyable to learn than dates and basic facts about regulations.
How can we make our learning valuable? By educating our financial services team members that they can make a difference in protecting their customers’ and neighbors’ privacy. They can influence their local communities by being situationally aware for AML rings that fund drug traffickers, human traffickers, and terrorism.
How can we make our compliance training more usable? Assuming the learning is more desirable and valuable in the eyes of our team members, ultimately, they will decide to implement the behaviors these regulations demand. Our team members lead hectic lives at work and home. If we make our compliance training more personal, perhaps we may see the desired behavioral change.