¶ … group work and group dynamics may be applied within a compliance audit work setting. This essay is illustrated with examples from my own practice experience in a fiduciary organization. These examples are drawn from group experience as an analyst with the Compliance Analyst Group that is conducting Patriot Act reviews on new and existing accounts. Group development, generally is more predictable than individual behavior. This is why we will focus on the developmental level that my group is presently at.
Quick Overview of Patriot Act Compliance
Patriot Act compliance is much more stringent for fiduciary actions. Due to liability and legal issues, our firm has chosen a single, integrated, software process from Metric Stream Solutions to demonstrate and document the organizations that we do business with are legitimate and legal to help meet Federal and international regulatory requirements. These requirements are set out in the U.S.A. PATRIOT Act, Office of Foreign Assets Control (OFAC) regulations, the Bank Secrecy Act, Financial Services Authority (FSA) Money Laundering Directives, and other global regulations that the U.S. is obliged to enforce under treaty agreements. Financial institutions that fail to perform and document such verifications face enforcement actions and regulatory penalties and also risk significant damage to their reputation, as well as resulting in customer dissatisfaction and defection. Needless to say, this is a team effort, hence the need for an effective PATRIOT Act compliance team.
Group Level-
Based upon the class methodology and since there is only a small difference between or four scores, then this indicates that the team's performance is highly variable. This then would likely mean that we are in the storming phase. That is the bad news. The good news is that due to the scores averaging in the 20s, we should be close to the norming stage. Unfortunately, due to PATRIOT Act stringencies, we do not have the luxury of time. We need to get to the performing stage as soon as possible.
Storming to Performing Quickly
Unfortunately, legal and liability issues are dictating a strong leadership role at this time. The recent audit by the Metric Streams Solutions audit team identified a key number of legal and liability compliance issues that have to be dealt with immediately. The legal team is also putting pressure on everyone now that that they have the Metric Streams report. While the Metric Streams audit has added pressure at this moment in the firm's history, it will also in the long run greatly aid our PATRIOT Act compliance by taking a lot of the guess work out of the mix.
Based upon the report from Metric Streams, as well as legal team and top management directives to lower level management, new leadership for the team has recently been appointed. Roles have been reassigned and we have a number of team building "release sessions" where members can express their frustrations during this period. Based upon Blair, the criticism will be required to be neutral, constructive and as friendly as possible while realistic (Blair). This will hopefully discourage personal oppression since team members will have it explained to them that the people in leadership are only doing their jobs. It is understood by the senior partners that a degree of conflict is inevitable and that it is alright to express this, but ultimately, the common good and the survival of the firm indicates that these issues (particularly the documentation about the source of foreign clients' money) have to be resolved. Luckily enough, some tense situations have been diffused (and critical personnel retained) and things are moving along more smoothly.
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