Happy Path

Fall in Line

I worked for a corporation. A corporation that was part of an industry. As with so many corporations and industries and workplaces with more than fifty employees, I was required to complete compliance training. Part of my job was to understand company policies and regulations. And by understand, I mean complete some painfully boring online courses so The Bank could say they'd fulfilled federal regulations.

It wasn't my first compliance rodeo. At my television job, there had also been company-wide mandated learning. Everybody would grumble when the email to complete the courses by a certain date was issued. Most of us would wait until the last day of submission and then pool resources. I always admired how something we all loathed became a team building exercise. When a group uses hive intelligence to avoid an undesirable task, you have to award points for ingenuity. I'm guessing the company wouldn't see it that way, but it meant one person worked hard enough to enable the rest of us to simply work the system.

At The Bank, I had no team to help me cheat the compliance police. Just as with almost every other instance at work, I had to go it alone. However, I did have the time to scroll through a staggering amount of information on bank protocol with supporting examples, so I just bit the bullet and learned about the industry.

Some lessons included supporting characters. There was the hamburglar with a striped shirt and eye mask, committing fraud. And the hacker with a bandana and an eye patch, like a hippie pirate. My favorite was the cartoon character, Blake. In each of his animated vignettes, Blake was the hapless employee who made blunder after blunder. Whoever animated poor Blake gave him a teenage boy's cracking voice to go with his middle-aged façade, further emphasizing his underdevelopment as a human.

I worked for hours each day over the span of a week to complete the compliance courses. One of the testers would walk past my desk and exclaim You're still doing that? He didn't have the courtesy to tell me the easy way out.

There were a couple bright spots in training. Aside from the hamburglar and the pirate and Blake, there was also some pretty amusing terminology. The best term, by far, was "smurfing". As a cartoon-watching child, I'd learned that the word "smurf" could be used to replace any verb or adverb in Smurf Village. Or adjective. Come to think of it, the Smurfs used "smurf" to mean just about anything and everything. However, in the context of banking, "smurfing" meant breaking down cash deposits into smaller amounts to avoid detection. In other words, smurfing was a form of money laundering. Did the term derive from the act of shrinking money to smaller amounts? Did it somehow refer to the blue dye used to mark money taken in a heist? Or was la la la la la la la la la la laaaa the theme song of money launderers everywhere? I'll never know since a quick Internet search didn't reveal the origin of the word and then I lost interest. I prefer the mystery, anyway. I don't even want to know which came first, the cartoon or financial institution term.

When I was finished, I'd passed skill-testing questions in five areas: reducing the risk, security and privacy, anti-money laundering (AML), integrity in action and managing operational risk. Along the way, I gained some knowledge about bank protocol and processes. I felt a little more in-the-know. That was in January.

In April, Charles forwarded a message to our group about compliance training. I deleted the email with a smug smile and imagined sticking my tongue out at my colleagues who had to take the courses I'd so recently completed. Especially the tester who had given me such a hard time for my glacial pace. Enjoy the hamburglar, suckers! Say hi to Blake for me.

About a week later, Charles brought up the courses during one of our meetings. "Did you get that email I sent about the training for contractors?" he asked.

"The compliance stuff?" I replied. "Yeah. But I don't have to take it because I did it not long after joining The Bank."

"That's good," he said. "Maybe you can help me with mine." Then we returned to talking about the budget or gossiping about CTV survivors or postulating on life.

The next week, a few days before the compliance testing deadline, I started to worry. Or not really worry, so much as wonder. Was I really absolved from taking the courses? It seemed inconceivable that I'd have to take them again so soon. Surely an employee wouldn't be expected to comply more than once yearly?

I waited another day before I finally gave in to paranoia and emailed the HR operations manager who'd sent the original notice forwarded by Charles.

MOLLY: Hi, Ruth. I know the deadline for compliance training is April 29th. I joined The Bank in late November, and did the training in January so I'm pretty sure I'm up-to-date. However, is there a way I can confirm that I'm not missing any courses? Thanks.

RUTH: Hello Molly. The new courses for F2016 did not come until Feb. 9. Any courses competed (sic) prior to this date need to be redone. I have attached the link for the courses. As a condition of The Bank corporate policy, it is a requirement for each Contractor to complete the following compliance training courses noted below...

God. Dammit! Apparently the brain trust that asked me to do the testing in January was unable to project a month ahead and recognize that I should wait for the latest release. I was not impressed. However, I decided that since I had completed the old version of the course not long before, I probably had a pretty good chance of successfully employing a method Charles liked to use in everyday dealings. The method is called "throwing it over the fence". When you're unsure what someone wants, take your best guess and throw it over the fence. The approach is one part attention-getter and one part passing the buck. It also made me think of how when I was a kid, instead of bagging the family pet's dog poop and throwing it in the garbage can, I'd often just throw the poop over the fence into the neighbor's yard. In the case of compliance testing, it meant I would use my lingering knowledge to jump ahead to the testing portion of the courses and make educated guesses.

Back to the drawing board, which was only a link away. I signed in with my still-active testing ID and chose the accelerated option designed for long-time bank employees who could skip the explanation and head straight to the retention testing. First question: Which of these AML schemes hurt small businesses most? I read over the three options. None was familiar. I dropped my head in defeat and started over with the first lesson.

An hour later, I heard a passing voice behind me, "You're still doing that?"