ABSTRACT

When it comes to following up questionable transactions or securing the necessary level of satisfaction with a client’s bona fides before on-boarding, compliance officers tend to encourage front-line staff to follow their gut; that headless brain which functions outside logic, hard evidence and pituitary analysis. Lenders also know of this emotion. It is not every borrower, after all, who will meet every requirement under regular rules. In fact, even though some borrowers meet all the requirements, the lender herself may remain uneasy with the overall lending proposal. It’s nothing they can put their hands on per say, but to all intents and purposes the discomfort remains. In a nutshell, the lender has a hunch the client can be trusted to keep their side of the bargain, or not.

In this chapter I lay bare my analytical framework and follow a hunch. The hunch being, that my reflections on the effectiveness of regulation in curbing the evil money problem are best decoded within an institutional framework. I also set out the way in which I went about gathering the data I felt would be useful to my analysis.