Compliance as a Commercial Asset
Anyone who has worked in compliance will have been called the Business Prevention Department at some point. (We know. We've made our peace with it.)
But before you reach for that label, try a thought experiment. What if excellent compliance was not a cost your business absorbed reluctantly, but something that actively set you apart from your competitors?
Every firm operating in a regulated sector is subject to the same rules. The AML/CFT Code applies to all of you. The FSA (ultimately) supervises all of you. The onboarding requirements, the due diligence obligations, the source of funds questions: your clients know they are coming, because they have been through it all before, probably with some difficulty.
Which means the playing field is level, and the question is simply what you do with that.
AggressiveSell Limited
AggressiveSell Limited operates on a familiar principle: get the client in the door, sort the compliance out afterwards. It is not cynicism exactly, more a deep-seated belief that the commercial relationship is the real work and the compliance is an administrative obstacle that can be dealt with once the important part is done.
After a slick first meeting, the client is contacted again. Then again. And Again. Piecemeal requests arrive for documentation they were not warned to bring. Questions come in ones and twos as different parts of the internal machine catch up with each other. The process drags. By the time the letter of engagement finally arrives, the client has spent weeks in a state of frustration, wondering whether the firm’s actual services will feel as disorganised as the process of engagement.
The best case outcome is that they still agree to engage and say nothing to anyone about the experience. That is the best case.
The thing is, none of this was malicious. AggressiveSell Limited was not trying to create a poor impression. It simply never occurred to anyone to think about the client’s side of the onboarding experience, because compliance had always been treated as a back-office hindrance with no bearing on how the business presented itself.
The better scenario
At another firm, something different happens before the first client meeting even takes place.
Sales and compliance talk. No, really, go with me here.
The initial screening has already been run. Any flags or likely information requirements have been identified in advance. When the client arrives, they have been told what to bring. The first conversation covers both the commercial relationship and the compliance in one go, because the person across the table understands the context of the questions they are asking and can explain it. As the bases are covered in conversation, eliciting information form the client is easy and collaborative. There are no loose ends chased afterwards, no second and third requests, no unexplained delays.
The letter of engagement follows quickly. The client, who arrived braced for the usual ordeal, leaves having had a notably different experience.
They are so surprised, they tell people about it. Not in a formal referral sense, but in the way that people talk when something exceeded their expectations in a sector where expectations are reliably low.
The actual cost of getting this right
There is no additional regulatory requirement here. Both firms are operating under exactly the same Code. The difference is not in the rules: it is in whether compliance is treated as a process bolted on at the end of the relationship or woven into it from the start.
The investment required is time for internal collaboration and a decision that the client’s experience of being onboarded is worth thinking about. For most firms, that is a conversation and a revised checklist, not a transformation programme.
The firms that work this out are not just compliant. They have turned an obligation that every one of their competitors shares into something that quietly, consistently, works in their favour.
That is a pretty good return on a checklist.
