Today we conclude the methods of coping with the often adversarial relationship that I, and most compliance officers, have experienced when interacting with New Accounts, New Business, Account Relationship Managers and Sales staff at financial institutions, and several types of NBFIs. Whilst I often am generally quite critical of the-end-justifies-the-means viewpoint of New Accounts staff, I certainly recognise that they are not going to change. The secret is to handle them with tact, and to establish positive relationships with them as partners in the client approval process. At the same time, to thine own compliance profession be true. This means that you keep the Accounts people honest by catching their clever tricks, and those of their prospective clients, and acting swiftly to deny entry to such clients, and committing to memory the tricksters and manipulative staff who engage in "creativity" when it comes to personal customer information. I found that, after a while, the more intelligent new accounts people develop a grudging respect for you and your skills. They still don't like it when you kick out what might have been a lucrative client of theirs. Way back when, most businessmen accused lawyers of often being responsible for the death of a deal; now, since 9/11, the compliance officer frequently faces such negative criticism from the people responsible for generating business. Remember this, if they like you in New Accounts, you're probably not doing your job.

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