Happy Halloween! In honor of the holiday, we are taking our compliance message in a bit of a . . . spooky direction. But our message remains the same: International transactions are inherently high-risk; they require constant attention and oversight for your compliance to be effective; and it is always better to put your resources into compliance than to spend them on investigations.

Speaking of Halloween, here are some interesting facts about Edgar Allan Poe:

• Poe ruined a promising start to an army career at West Point by spending his time writing mocking poems about his instructors rather than finishing his assigned work.
• Poe often wrote only after placing a Siamese cat on his shoulder.
• The Baltimore Ravens are the only major sports team to be named after a poem, Poe’s “The Raven.”
• And most importantly, Poe turned down a promising career as a chief compliance officer. Don’t believe me? Check out this recently unearthed initial draft of “The Raven,” and decide for yourself!

Internal Investigations Are a Poe Substitute for Compliance

Once upon a midnight dreary, this Compliance Officer pondered, weak and weary,
Over a list of quaint and curious compliance chores —
While I nodded, nearly napping, suddenly there came a tapping,
As of someone gently rapping, rapping at my chamber door.
“Tis some auditor,” I muttered, “tapping at my chamber door —
Only this and nothing more.”

Ah, distinctly I remember, it was in the bleak December;
When fiscal-year matters come to the fore....

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