Big banks are not doing too well these days in the compliance arena. From Barclay’s and the burgeoning LIBOR manipulation scandal; to HSBC and its money-laundering operations for drug cartels over the past several years; to the ongoing reckoning of JP Morgan and its $5 bn+ trading loss that it is still trying to extricate itself from several months after publicly announcing the loss, big banks seem to be more in the news these days for compliance failures rather than successes.

I saw an article in The Rector Factor section of the July 27 Houston Business Journal, entitled “Prepared company perspective for lenders, investors”, by columnist Bruce Rector that discussed some ideas that companies might draw upon when looking for financing. I thought it would be helpful for the compliance practitioner to use as a guide when putting together a budget, or other, request for funding a compliance initiative.