‘Good’ regulation

Studied under David Jackman for the Diploma in Anti money-laundering (Module 4). See more about him at the end of this article.

It is my belief that a viable culture is vital for successful compliance/regulation. Hence, I am following up on his teachings on regulatory maturity (for possible further research). He states 4 stages/levels from the document Ethics for Regulators. (2016). https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/553826/David_Jackman_-_Ethics_for_regulators.pdf [UK government site].

I quote here the middle two stages and highlight a tiny bit of the final stage.


2. Procedural

  • Question: What do we have to do?
  • Unthinking, mechanical compliance
  • Dispersed decision-making /decision-sharing
  • By the book – black or white answers, ticking boxes
  • Bureaucratic and costly
  • Jobs-worth, inflexible application of principles
  • Culture of dependency on ppolicies and procedures
  • Outsourcing ‘conscience’

3. Embedding

  • Question: How can we be more effective?
  • Making the business case
  • Reputational repair or building trust
  • Helps in delivering on objectives, no just a cost
  • Part of decision-making at all levels
  • Staff give space to grow and trusted to make decisions
  • Judgment led
  • Public accountability and kpis
  • Long-term planning of developing principles

4. Values-led would involve:

  • Question: What do we want to do?
  • Good habit not audit driven


Related posts/Information:

Personal Data Protection Act 2012 (PDPA) – Singapore

Specimen Paper and Reflections – Anti Money Laundering


[from the main source article] “Regulatory Maturity:
1. Effectiveness of the regulatory body in delivering its stated objectives,
including the sophistication of the regulatory tools and techniques used
2. Maturity of the relationship between regulator and regulated, and other
3. Integrity of the internal regulatory culture, including the degree to which
the seven principles are embedded


David Jackman. Company Overview of Jersey International Business School. https://www.bloomberg.com/research/stocks/private/person.asp?personId=61166528&privcapId=102276049. Bloomberg.

Read an article written by him in 2012. David Jackman: Business won’t be ethical until it shares society’s values again. http://www.independent.co.uk/voices/commentators/david-jackman-business-wont-be-ethical-until-it-shares-societys-values-again-7965044.html. The Independent. UK.

David Jackman. Strategic Advisor. Meet the ICA Advisory Committee. https://www.int-comp.org/ica-advisory-committee/meet-the-ica-advisory-committee/. International Compliance Association. International Compliance Association. London.


[Reflections] Reportage – 2008 Subprime Crisis

Swimming with Sharks

I began reading this for two reasons – the sensationalist title and (perhaps less importantly) trying to understand the financial earthquake that took place.

I ended up though with sociological/anthropological insights into banking. Luyendijk apparently researched electric cars via the “idiot’s” or “dummy’s” approach earlier. It is replicated here. He went through an excess of 200 sources from the front, middle to back end; the regulators (none other than the Bank of England); and even partners. It is largely a British/European angle (the author is Dutch).

The book reads somewhat like an emotional roller coaster; and no, not all of the bankers are like sharks; neither were all of them responsible for the breakdown in 2008 (or 2007 depending on your timeline). If what the bankers described were true, then we went really near the (financial) abyss.

Read it yourself – especially if you plan to go into banking. It is also rather recent and up to date; published in 2015.

A related post on the American banking scene here. For the generic Singaporean banking context, consider <The Ultimate Banker> by Edwin Lim and co-authored with Leong Kaiwen and Edward Choi. (2012). Lim, the banker, was diagnosed with ‘motor neuron disease’ (fatal) in 2010.

Further references:

Marcello Estevão. (Dec 2015). The Jaws of Finance. https://www.imf.org/external/pubs/ft/fandd/2015/12/pdf/book1.pdf. Finance & Development. International Monetary Fund.

Review in The Telegraph by Nicholas Blincoe – Swimming with Sharks: My Journey Into the World of the Bankers by Joris Luyendijk, review: ‘prophet of doom’.

The original blog by the author (last update 1 Oct 2013) – The Joris Luyendijk banking blog. The Guardian.