Compliance at Banks, Company Law and Financial Markets Law Observations on Whether the Law Sheds Adequate Light on Ownership

markdownabstract__Abstract__ In 1999, I started being professionally positioned as a ‘compliance officer’ in a bank. My career in the world of the compliance function in banks began in an international private banking environment, during which phase I predominantly focused on assisting the bank’s management in preventing the private bank from being (mis)used for money laundering.1 In my capacity as the global head of the compliance function of ABN AMRO’s worldwide private banking activities, I was among the protagonists of the Wolfsberg group of banks. This group assembled the banks which at the time combined the greatest spread in businesses with the greatest geographical footprints.2 In subsequent positions within the ever expanding construct of the compliance function in ABN AMRO, I gained exposure to a much wider ambit of the compliance function in banks, participating in and witnessing first-hand the iterative process of ‘(re-)engineering’ both content and process