‘The Picture of Dorian Gray’ by Oscar Wilde is the first grown-up book I fell in love with. For those who aren’t familiar it is a lush and louche tale about a deal with the devil. Dorian sells his soul for a portrait; not just any portrait of course but one that immortalises dear twisted Dorian by absorbing all his ageing and a fair bit of associated naughtiness. Not surprisingly, bereft of consequences he really pushes the boat out and things go awry. While the majesty of the prose captivated me; a fireworks display held in the palm of my hand, the underlying message of temptations, morality and consequences has lingered with me to this day. In modern parlance we might refer to them as ‘Key Performance Indicators’ (KPIs).

An appraisal can be like painting a portrait for someone. Portraits can be flattering or not, but the best ones show whether you have been making an honest effort recently. I have had a few great appraisals which I left feeling invigorated and newly focused and a lot of mediocre appraisals, basically with me being told whether I was receiving a bonus, pay-rise, promotion or not. I have also had one or two appraisals that I entered like a happy puppy, thinking I had worked hard and would receive a pat on the head and bank balance. Then time spun forward to me leaving that meeting with a face like that guy in Edvard Munch’s famous painting ‘The Scream’; the word ‘Whhaaatt?! bouncing around in my nonce. Given that I do have a particularly thick nonce (on a good day I like to say that I am ‘focused’) I guess that I should be grateful to those people. It is to their credit that I am now super careful with the appraisals that I have to do. I don’t want anyone leaving one that I have given with a face like that. I paint carefully and I am continually learning better technique.

But prepping always comes first, and prepping for the next appraisal starts straight after the current one. I note how people have responded to my feedback and adjust my thinking and goals for them accordingly. If I am worth my salt as a manager, then I should have a bigger picture and every single person that works for or with me should fit (tightly or loosely) into that. I am deeply committed to the contentedness and focus of the people working for me and believe, if you hire the right people, you should never have to micro-manage (hiss.. bad word). Little, light and constant brush strokes create the most detailed pictures.

Tone and environment are important on your canvas. I like to gently check-in with peoples’ progress and the team mood on a regular basis. A coffee in hand chat on the way past their desk is a good tone to strike. Informal and clearly intended to be brief. We all have our schtick and, depending on the mood, (clearly if someone has had a bereavement then a different tone is advised) but lighthearted phrases like ‘Anybody’s world blow up today?’ or ‘Anything fabulous I should know about?’ are go-to’s for me. This opens a door for conversation without pressuring anyone. If someone’s face falls, then this is probably a time for a more direct question or, if they aren’t keen to chat in public, an excuse for you to need someone’s help picking something up from the cafe. I generally feel that chats in offices with doors closed are only for the serious stuff. Guys tend to be a bit stickier with the chat but a door open policy is a good one..

Obviously, if your department is set up properly, then KPIs that you go through in an appraisal should serve the ‘Big Picture’ of your firm (regulators really like to see this on their inspections too). So, in the run-up to the appraisal, it is useful to gently remind people about (even offer to help with) the progress to their KPIs, especially if you feel that they might be lagging.

Obviously Sod’s Law is a fundamental power in the universe and things generally don’t go to plan. So, once you are actually in the meeting, and if you have prepped on your expectations going in, then you should give them some room to talk first with a phrase like ‘So, before we get into the points is there anything you feel I should know?’. I have spoken at length about the need for compassionate listening. Basically they should understand that you care (if you are a miserable, hardhearted sod then fake it till you make it); they should feel that they can trust you, that you are focused, fair and fundamentally positive about their abilities, even if they are at a lull (we can leave firing stuff for another chat).

There is of course the issue of intentions and consequences. In a happy world they have sparkled every day that they have come in the door and, if you are a grown-up then you will be big enough to say so. As someone who believes in constructive competitiveness, I find it strange that so many managers and coaches I know seem to take real pleasure in finding things wrong with good people, so they can ‘put them in their place’ or some other nonsense. I do not agree with this approach. Be nice, be constructive or talk to someone about why you need to take others down. If you are the manager, then you should be the grown-up. Give them carrots, give them stretch goals, let them fly. Yes, even if they are better than you. Be proud of the contribution that you’ve hopefully made to their success.

On the other end is the constantly under-performing member of the team. We have to do what we can to help (especially if we hired them ourselves). Sometimes it is just a case of people being in the wrong place and a better place can be found for them. I have done this on occasion. But, if consistent and concerted efforts don’t bring that person up to speed then a door must be compassionately (if at all possible) found. At the end of the day you are the gatekeeper for the performance of the team.

Now, I have managed a few regional teams and it was important for me, given our complex situation across the region, that my staff knew I had their backs when things went wrong, especially if they had done everything right but the situation had gone wrong. If they had done something really meat-headed then we would definitely be having a quiet chat about that. Never take a knife to them in public, even if they have done something really dodgy. If you have to say anything to the world-at-large then say that you are dealing with it and release them from their obligations quietly and away from the light. At the heart of it, of course, most people appreciate not being outed but I just think that, whatever the environment, people need to be shown respect. A simple concept that often gets lost in the heat of argument and ambition.

Overall, one of the better management days that I had was a comment one of my staff members made as she left my office following her appraisal. I had asked if she was happy with it, she replied simply ‘Of course, there are never any surprises with you’. I was deeply pleased by this comment. I have always worked hard to make sure that my staff knew me, they knew that I would do my best for them, that I wanted them to push themselves and achieve their potential (yes, even if theirs exceeded mine).  I aspire every day to paint well.

I do wonder what will they think of us in a couple of hundred years. I personally live in hope that humans will still exist and they will think well of us. I also hope our generation will be remembered as a huge turning point in awareness and that the current axis of evil comprised of climate change, single-use plastics and Donald Trump’s hairstyle will be long forgotten. But how are we committing ourselves to this shiny future? Specifically, how do we treat our future i.e. youth? One of the most vivid images of maltreatment that we have looking backwards (thanks in a large part to Oliver Twist) is of Victorian times and Victorian workhouses. We tend to assume that things have improved; but have they? More importantly, can we realistically be better?

Firstly, shamefully, children still live in poverty. A huge topic with an embarrassment of fingers pointing in many directions. I have spent some years looking at this in relation to the sociology of crime, and plan to return to this discussion soon, but it is not the topic for today. Today I want to talk about doctors, lawyers and accountants. Okay, granted, not your usual suspects but bear with..

These ideas bubbled to the surface after someone mentioned a video that I had sent them some months back with the comment ‘I agree, Millennials are such an entitled bunch! A friend of mine at a law firm said that the young lawyers didn’t want to do filing!’. Now, I can’t remember the exact reason why I sent that video link over but I am quite certain it wasn’t fishing for that response. Why do we, as people, always swallow the judgemental bait before the compassionate one?

I was baffled.. ‘But why should they be doing filing? Nobody in the developed world should be doing it’. Okay, yes, legal firms are notorious for their reticence about taking on technology but filing, really? Many years ago I was the key person for a litigation case with tens of thousands of physical files. This sheer inefficiency of this as a forensic measure (the amount of time I spent trying to retrieve – not always successfully – important files from others) should not be inflicted on anyone in this day and age. But it is. Crazy. Scan it securely in. Optical Character Recognition (OCR) is already good and gets better every single day. Those lost and forgotten files are a thing of the past, and you can do word, name and pattern searches. This is just scratching the surface.

People say to me that the young should ‘pay their dues’. But for what reason? The previous generation defined themselves by their ability to run forever on the Great Hamster Wheel of Work. Did it make us happy? Everyone will have their own take. Perhaps it was necessary then – I doubt it – but is it now? From my point of view the youth should be given the opportunity to define themselves more meaningfully. We should help them to be them, not us. In doing so, hopefully they can avoid and/or undo our more colossal errors.

As a result of a connection to Cambridge University, I have been fortunate enough to spend many years with some of the finest and most driven young minds on the planet. As everyone knows, this work starts at least a decade before University. A recent study guide recommended 4-5 hours of study a day, outside school hours. If they are starting at 8.30 and finishing after 4pm, then with the extra time that is longer than a working day and they are children. People have described their children regularly in tears of exhaustion and stress.. from as early as the age of 11. Modern workhouses anyone? Also, due to the ever increasing competition to get into the University and on the University itself to compete on the international stage, the pressure on these young people just increases.. and can only be described as beyond intense and many suffer serious mental distress. I am often moved by their incredible discipline and their real desire to contribute positively once they leave the hallowed halls. In short, I believe that they have paid their dues by the time they have gone through all this.

There is the issue of entitlement. It wasn’t my path, but in England most students arriving at the top tier universities (rightly or wrongly) will have had over a hundred thousand pounds spent on their education. It takes a village. They don’t just think they are entitled, they just are entitled. It’s not a dirty word, it’s a fact. So why seek to treat them in a way that doesn’t celebrate those decades spent refining their minds? Please, let’s celebrate and utilise it..

Coming back to the issue of their minds, Psychological Science reports that working verbal and visual memory working tasks plateau in our 30’s. These are key factors in all of the expert professions, so why are we wasting these sparkly brains on filing? Someone else may be in a life position to do these things better. Where they are more content to slow down a little. Why not bring in two empty-nesters to job-share and scan those libraries in? They will be happy, reliable and probably grateful to get out of the house. They won’t frolic (god forbid) and they are more likely to stick around.

Other people have laughed at the fact that the youth want to make an impact. I don’t see why they shouldn’t at least try, and why we shouldn’t help them. Otherwise, how can things change? And things will change, especially with AI breathing down our necks.

I think what most people are really reaching for is the fact that they want the younger ones to respect the older generation. Speaking from my own experience, my respect was not earned by making me work stupid hours (for one case I averaged 14-18 hours a day, seven days a week for up to four months at a time.. I was ill for almost a week afterwards). A good example of respect was a senior lawyer coming in and looking at the tower of paper containing multiple rebuttals that I had prepared for him. He simply asked me ‘Is there anything substantive?’. I thought a moment and said ‘No’. I gave him a brief rundown and he agreed. Smarter not harder. Efficient. Respect. I went home at the previously unheard of time of 4pm that day. Yay, daylight on my face!

The key ingredient in all of this is the nurturing role that the existing staff can have. I am thrilled to see the uptick in mentoring being requested of me, and on general offer. As I have said before, I was blessed as a young person to receive amazing opportunities to contribute to (sometimes globally) important issues. This all happened under an umbrella of spectacular mentoring and guidance from senior staff, all whilst I was in my twenties. The light that these young people bring should be directed, not extinguished so that they can burn out, hate their jobs so much by their mid-thirties that their only goal in the working week is to be able to get away for golf on Fridays. What a waste.

Yes, I fully understand that it is physically difficult to unwind the large and unwieldy legacy systems that we have but I wonder how long it will take to unwind the legacy thinking and bring these young professionals out from the workhouses into the light?

Our local rowing club is very small with a general intake. There is no sponsorship, no big boathouse and no paid coaches; just a happy and diverse bunch of hard-working volunteers with an open door policy and a shared love of rowing. To the casual observer it is nothing remarkable, yet over a short period of time the handful of young rowers that turned up regularly wound up in top boats at their universities or on the national team either immediately or within a year. As a result, the club came to the notice of the national talent programme and it now has a dedicated paid coach to bring on the talent of the area.

So what made this club different? A number of things came together but I personally believe that an obsession with getting the basics absolutely right at the start and a really positive culture was at the heart of it. So, how can we translate the success of this little club into a corporate environment?

Getting it right at the start

Starting at the ground level, there has to be an ethos of openness, so when you hire don’t just rely on one hiring group, throw your net wide (maybe even subscribe to a novel community outreach whose ethos mirrors yours and/or let people know that your door is open for wild-card superstars) and be clear about what you are hiring for. If you are serious about hiring well then you must address unconscious bias, remember you are not hiring to make friends but people you respect to do the job. It is not about you, it is about hiring the very best person to fulfill the stated requirements of a job. If you are concerned about bias (and if you aren’t then you should be) then there are some helpers around. While I don’t believe in removing bias related text to get people hired, I do think we can use it to educate ourselves. For example, we can work alongside tech like Talent Sonar or Textio. Have all colleagues trained up on diversity and bias. Assign two the same piles of CVs. Have one colleague work with the redacted lists and one with the original CVs and then record and openly discuss the differences. Learn and share.

Obviously, there are specific and general considerations when hiring. There are the applicant’s natural or acquired skills and talents and whether these fit the specific requirements of the role. You will get those through the experience and/or psych tests. For me though, general talents like clear evidence of determination, curiosity, compassion and adaptability (some people like the term ‘teachability‘) go a long way, especially if the choice comes down to the wire, especially in an increasingly technological world. I have also gone on at length about challenging traditions (Making the most of Millennials) and using common sense when hiring. And let’s keep all the doors open here, alongside gender, race and age balance there is a further wealth of willing talent on offer who are generally completely shut out simply because they are mentally or physically disabled. Not everyone is so blinkered though, our local supermarket hires people with disabilities for various roles and it is worth noting that the lovely man with mental disabilities who puts our trolleys away is the only person that I recall being there for the many years I have been going to that supermarket. He is always chatty, always happy (because he loves his job and meeting people) always remembers a face and always makes my day. If we actively believe in creating a rich environment where people know they can feel safe then we should really think about what each job really needs. And I don’t mean safe to sit back and dodge things but safe to give a considered and constructive opinion on any subject.

There is a lot of focus on executive training but not as much on graduate training which baffles me. I think that this is a huge opportunity to instill and improve both the culture and performance of a company. So much so, I am currently developing a programme on it called ‘The Glass Ceiling Project’. I have aimed it at anyone entering work and dealing with obstacles and am hugely excited by the great feedback I have been getting. Watch this space! It may be considered old-school to have on-the-job training (it certainly seems to be one of the first things that falls off when budget cuts come around) but all the big tech guys like Apple are also famously very hot on this, so maybe there is something to it…? There is certainly something to doing it well. I think that making sure that your current employees are part of this training (in both the development and the delivery) is extremely important too to maintain continuity and communication. Obviously there is mentoring but promising younger members should also be given opportunities to do cross-departmental work and maybe take notes at senior management meetings. This learning can be relayed back to the home department team. Experienced staff can also give talks to other staff on topics or issues that are relevant to the company. Maybe even just a great anecdote about a deal or a process that could be considered best practise.

Really positive culture

Vision from the top is key but, as I saw when I was investigating companies for regulators back in the day, so often there would be this sexy but lonely motto adopted like ‘Being a top five firm in the country’ which had no ‘how-to-achieve-this’ dialogue attached to it (or it would just be something that only related to the sales force selling more… yawn) which often bore absolutely no relationship to the company as a whole. The aims of every single member of staff should be aligned to support the clear aims of the company. Yes, of course these should be SMART (specific, measurable, achievable, realistic and time-based) but everyone should really feel that they are contributing to the big picture. People need to understand, agree and commit and this should be nurtured. Facebook is a good example there, it has obviously had a very stable vision from the top, with a very low management turnover. Big focus on community and famously, connectedness. Notably they don’t tend to hire directly into the top executive roles; they hire at least one level below and then people work up into the top roles. Again, grow your own.

Coming back to natural talents, I am not a fan of flat structures or collective leadership but I do believe that corporates should be structured so that siloes don’t form. Having mid-level operations people (one of my favourite jobs was COO for Compliance for Asia for an investment bank) is one excellent way and achieving synergies and maintaining communication between departments. For example, instead of installing one learning platform per department, we were able to save many millions by creating one system which served three different departments across the region.

We all have our roles and very few are natural leaders. I’m not one. I prefer to work in operational and support roles but, because I talk like a dam breaking and have an opinion on just about everything then people have put me forward. It took me a long time to understand, accept and ultimately value my true nature in our ‘Top Dog’ society. Society has a lot to answer for here. If you see all the popular courses (and certainly all the advertising) it seems that we are all very keen to make everything about ourselves, our money, our status, our success but the happiest staff and people are those who feel that their contribution is an integral part of a bigger picture. That they are valued and that they belong to a community, preferably one that is achieving (This article is a lovely example) or even better, making a positive impact! So, I believe in a flat starting point but fluid response to the well-communicated, coherent needs of a project or changing climate. People who are performing must be incentivised in meaningful (i.e. not necessarily monetarily!) and those that aren’t performing are given opportunities to find better outlets.

If you do find yourself in management and you want to develop your own talent internally then, once you have hired these amazing people, then ‘get out on the floor’ and really listen to what they are saying. Don’t assume that you know better, embrace and celebrate people’s contributions. If you do this properly you will really have a finger on the pulse of how well your company is doing because, unlike what all those courses are trying to tell us, in a company it is not about us, it’s about how what we can contribute fits into the big picture.

Finally, encourage everyone bring their whole self (within reason) and that may mean that a single mother will leave early to pick up her children or that a ramp needs to be brought in for that amazing programmer who uses a wheelchair. It also should mean that middle-class white people don’t have to turn up in corporate suits and conservative haircuts. It turns out that a little rebellion is a good thing (See ‘How Small Acts of Thoughtful Rebellion can increase Power and Status‘. Thanks @Cath Bishop) even if that means pink hair in the office.

What do you see when you look in the mirror? I see my flaws first, that I should have had more sleep and that the bathroom mirror, or the morning sunlight is probably too bright. Okay, I lie, it’s England, the morning sunlight is never too bright, if it makes an appearance at all. Sometimes it is more about who I see. I am not about to win any beauty contests, but I like who I see in the mirror. I can see my father’s full upper lip and my mother’s clean jawline. He is, and she was, deeply kind, even when being brutally honest, deeply loving, and endlessly curious. I like seeing them in my face.

As you may know, I am a criminologist and over the years I have dealt with and seen some dark things. Two years ago, I was preparing to do a doctorate on bias in judicial decision-making. This came about chiefly as a result of a heart-breaking year trying to establish what the International Human Rights were for prostitutes (Spoiler Alert: Sod All). Over that year, and a couple of subsequent years spent in that shadow world; a world that so few of us actually see but which apparently collectively fascinates us. This is attested by the way that people react when I tell them that I am a criminologist and the endless conveyor of polished television dramas with artistically placed (and generally whole) victims and some very interesting ways to creatively splatter blood. The reality however is yes, generally overwhelming, as you would expect, but also (sorry) soul-deadening. Most medics I know have quite morbid senses of humour. But I dodged that side of things, despite some juicy offers (sorry) and wound up in the criminal justice system side of things thinking I could make a difference and, after some years of sitting in courts listening to rape and abuse cases, and a whole other type of soul-deadening, it came to me that the outrageously biased decisions that I was witnessing might not be the product of monsters.

Full disclosure, I do have an inside track on this one. Having been attacked in my late twenties whilst on a morning stroll, quite soundly beaten, and left bleeding on a side-walk I know what it is like to go into shock and lose control of your body (thankfully not completely if you take my meaning) but not your mind. As a result, I have a very clear view of how your personal sanctity can vanish in a moment. I also fully understood why those women didn’t fight back. It was that their understanding of the polite world was shattered in a second, they couldn’t conceive of what was happening to them, so they just went into shock; big-eyed bunnies in brutality’s headlights. But the judgements were just horrible to listen to. Shivering fifteen-year-old girls were painted as wanton sirens luring young men into their cunning lairs whilst parents who attended – as ever, so many of the youngsters only had one if any parent there – sometimes cried quietly but generally sat stony faced in the gallery. Why? Simply because those pale and generally thin young girls weren’t covered in bruises like those judges, juries and defending lawyers wanted them to be, that they just lay there. So, in the eyes of those who had never been to that place, they had consented. I was speaking to one of the ushers at the Old Bailey one particularly upsetting day (gang rape) and she revealed, that in five years of ushering there, that she had never seen a rape case successfully prosecuted.

So, why do I not think that these judges were monsters? Because I know (and science backs me up) that most of us really believe that we are fair and good people. I also know that we are all products of our history and our upbringing and that, most of the time we aren’t aware of our own assumptions and biases. Yes, even when they might be blindingly obvious to others (particularly those on the receiving end). So, the intention for my PhD study was to hold up a judgment and decision-making mirror, admittedly a dark one (heavily focused on judgment, get it? Okay, not my best.) but definitely an authoritative, scientifically backed one, to these judges.

The more I understand about artificial intelligence, the more I agree that it is our dark mirror. This is not a new idea, but I don’t think that we have considered the full depth of that mirror. Massive historical data-sets might not definitively reveal my father’s full upper lip and my mother’s jawline (yet) but they can certainly identify where we came from. And where we come from definitely impacts the patterns of our inspirations and in-built biases in both thrilling and mortifying detail. But it goes further, AI is our baby yes, and as a result, it is subject to both nature and nurture. We have identified the historical ‘nature’ in the deep cracks in the data sets but those are quite easy to address. Now we need to consider the nurture. The ‘training’ of AI is being done by young programmers and data scientists and we need to consider whether they need ethical training too. I was incredibly pleased to see that this idea is being looked at in another context recently and was very impressed by both the passion and the compassion of those who spoke of their work with parliamentary committees.

Back to the other point though, don’t mistake my intentions, I don’t want to wade in. I am a huge believer in, and backer of, the young. This is particularly because, as a young person, I had a couple of great mentors and was given massive responsibilities and opportunities to be involved in and influence policy-making way above my measly pay-grade. This was however mainly because I was (almost) the only person of my level, and a few levels above, at that time in my Hong Kong organisation who wrote English fluently (the other guy there just wanted a quiet life.. Ha ha.. Not me!). As a result, I absolutely believe that more young people should have this opportunity. What I see though, especially in the legal and financial worlds is young people’s intellectual fire burning out in years of long hours and mind-crushingly banal workloads. The world wars may have left us alone at this time, but young people are clearly still the cannon fodder for our stupid decisions.

AI can and is helping us here, so, let’s make smart decisions here. How best to use all this burning intellectual property? How would I use it for the judges I described? Well, I am pleased you asked… It might surprise you to know that I actually wouldn’t throw judges out. There are centuries of useful stuff under those manky old wigs which must be tapped and folded into the consciousness of AI. All cases are also not created equal, but yes, some types of cases and judgements could more easily be ‘assisted’. There is just so much potential. There was a fantastic study done by Cornell recently (which is definitely worth a read if heavy methodology and research is your thang) on how prison populations could be substantially reduced with the assistance of machine learning. Many years ago, whilst studying judgment and decision-making I learned of another study in America which was using computers (at that ancient time) to improve the decision-making of young doctors. I believe that the same should be done with anyone in the mix to be a judge. I still think that humans have a role, because we are supposedly more human, yes? And sometimes we are. I think it is great that young data scientists can come into these dusty, mote-filled worlds, bring light and honest reflection, because they need fresh eyes. I still remember the horror, in the first year of my Law studies, that rippled through the huge lecture hall when we discovered that delivering justice bore virtually no relationship to fairness or ethics. But it was more frightening how quickly we came to accept and engage this institutionalised lunacy (definitely a cautionary tale). Personally though it was definitely part of my decision not to practise Law after my graduation. I appreciate the intellectual cut and thrust, but it isn’t really fair if you are never the one who bleeds. Thus, my point about needing uncalcified minds.

I believe we need to give but guide freedom. There is wisdom in our noggins but how best to pass that on without stultifying the result? I am also a believer in mentoring but very few of us are good mentors. I try hard to be and get some wonderful feedback, but it is ever a learning process. Maybe the answer is that we develop a mentoring programme that helps and guides these young minds? Who knows? Bearing in mind that true scientific discovery involves great ideas and a lot of trial and error, we must absolutely guide them to fly, flail and fail. So many questions but all I know for certain is that if we can hope to make the best of this amazing new tool for honesty then we have to look in the mirror and embrace both the good and the evil we see there.

Twenty five years ago, when I first started looking at financial fraud, one of the largest problems facing regulators was that of jurisdiction. Getting information regarding off-shore bank accounts being one of the best examples of this. Despite the time that has elapsed and the brain power and effort that has been thrown at the problem, the situation appears to have intensified rather than resolved itself and regulators generally have themselves to blame.

My frustrations with this situation are manifold. Firstly in this same time period the ‘rogues’ (as I prefer to call the criminal underworld) have recognised and utilised the borderless potential of the virtual world in stark contrast to the regulatory obsession with physical location, particularly when drafting up legislation.

Yes, there have been numerous Memoranda of Understanding (MoU) drawn up but regulators have not taken the virtual leap on the legislative plane. Yes, the European Union did go some way to ironing out some wrinkles but just when things were almost looking up then we slid back into Brexit and different national interpretations of the same legislation. One example being the approach to research being promulgated by MiFID2. The Financial Conduct Authority (FCA) set a much stricter tone to the legislation in the United Kingdom verses the softer approach taken by the Autorité des Marchés Financiers (AMF) in France. Why could this not have been aligned earlier?

The central point here is, that within the same timeframe the rogues have finetuned their use of the information superhighway that is available to all of us, a crippling amount of regulatory brainpower has been tied up on compounding the problems of jurisdiction. The ripple effect down the line being further wastages of time, effort and brainpower trying to understand differences and complexity where it should be used to simplify and streamline.

Within the anti-complexity argument, I would suggest that the vast majority of MiFID2, MAR and MAD requirements are redundant. A number of commentators are suggesting that the amount of reporting required is restricting liquidity and crippling the industry and that it is disproportionately onerous to the smaller firms. Perversely it is also creating an incredible burden on the groups that are trying to enforce it.

It is one thing that regulators are being accused of strangling their own raison d’être but it is just befuddling that they appear to be strangling themselves in the process. The regulatory predilection for martyrdom should be balanced with a pragmatism concerning how best to utilise their own resources and those of investors and the markets themselves. I firmly believe that the vast majority of reporting would be superfluous if proper investor education and market supervision were adequately supported.

Quite frankly I blame the legislators. I contributed to and sat in on a good few policy discussions in my early years and one of the most enlightening involved the identity requirements for the establishment of an online trading account. We blithely rattled off the usual list of passports and utility bills being shown in the original form, content in the knowledge that we were protecting the investor specifically and you know, saving the world in general as usual. Then my boss at the time decided to test it out for herself and she came back quick smart, armed with the feedback from the street that this approach just wasn’t workable in the modern world. That was twenty years ago yet we as an international community don’t seem to have assimilated this knowledge. We absolutely have the knowledge and the technology to create a better and more streamlined approach. We just need to take the leap.

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