Skip to main content

The best best bad plan that we got

I enjoyed going to the cinema last Saturday night to see a film called ARGO. This Oscar nominated film tells the based-on-true-life tale of how CIA agent Tony Mendez (Ben Affleck) extracted six American diplomats from the Canadian Embassy in Tehran. Mendez’s plan to get them out is to create cover identities for the diplomats as a film crew for an in-production science fiction film.

There are a myriads of problems with this plan, not the least of which is that it depends on putting a fake science fiction film into production in order to fool the Iranian security forces who are scouring the capital to capture the stray Americans. The film gets it biggest laugh from the discomfort this plan raises in the Washington bureaucrats and the open-minded embrace from Mendez’s two Hollywood partners.

Once inside the meeting with Vice President, the politician is skeptical and openly wonders if they don’t have better a better, to which Mendez replies, “This is the best bad plan we’ve got.”

It got me thinking about COLPs (sad but true). Even if you have a poor Compliance Plan............a bad plan is better than none at all.

Comments

Popular posts from this blog

Argie Bargie over Home Information Packs

In response to a question from Conservative MP David Amess on what methodology would be used to use to evaluate the effectiveness of the Home Information Pack programme, Communities and Local Government Minister Ian Austin was involved in heated argument. The wording of the debate ( reported in Hansard ) makes interesting reading, so I thought I would share it with you : Mr. David Amess (Southend, West) (Con): What methodology his Department plans to use to evaluate the effectiveness of the home information pack programme; and if he will make a statement. Mr. Andrew Mackay (Bracknell) (Con): What methodology his Department plans to use to evaluate the effectiveness of the home information pack programme; and if he will make a statement. Mr. David Jones (Clwyd, West) (Con): What methodology his Department plans to use to evaluate the effectiveness of the home information pack programme; and if he will make a statement. The Parliamentary Under-Secretary of State for Communities and Local...

Paperwork is not a shield: Why your SRA aml audit demands more than just a dusty manual

The Solicitors Regulation Authority continues its aggressive crackdown on financial crime with a recent fine issued against Whiteheads Solicitors (Staffordshire) Ltd . This decision serves as a stark reminder that the regulator is looking far beyond simple paperwork during an SRA aml audit . The firm was fined 2,584 GBP plus 600 GBP in costs following an investigation into its compliance with the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017. While the firm had a firm-wide risk assessment and general policies in place, the SRA identified critical failures at the matter level. Key compliance failures included: Failure to conduct adequate client and matter risk assessments . The SRA found a consistent pattern where the firm failed to sufficiently assess client matter risk levels as required by Regulation 28. Inadequate scrutiny of source of funds . In one specific property transaction, the firm failed to properly investigate the origin of funds provided by ...

The High Street Practitioner’s Guide to Surviving the FCA

For a sole practitioner or the MLRO in a small high-street firm, "AML compliance" often feels like just another mountain of paperwork standing between you and your actual work. When you are juggling a heavy conveyancing caseload, a sensitive probate matter, and the day-to-day survival of your practice, the last thing you need is a new regulator with a reputation for being data-heavy and "zero-tolerance." But the ground is shifting. As the Financial Conduct Authority (FCA) takes over AML supervision from the SRA, the "high-street way" of doing things—relying on long-standing local reputations and gut instinct—is being replaced by a requirement for hard, documented proof. The end of "I’ve known them for years" In a small town, you often act for the same families for generations. You know their business, their parents, and their reputation. Under the old mindset, that felt like enough. Under the FCA, it isn’t. T...