Book Review - Policies and Procedures Regarding Compliance with Applicable Anti-Money Laundering Laws and Regulations

Menendez’s most recent work, “Policies and Procedures regarding Compliance with Applicable Anti-Money Laundering Laws and Regulations”, lacks the energetic drive of some of his earlier works such as “Internal Audit Guidelines and Procedures” and “Sarbanes-Oxley Compliance and You.” “Policies and Procedures” is the story of an organization that seeks to establish a policy regarding compliance with applicable anti-money laundering law and regulation; it unblinkingly addresses the paradox of how an organization, while made up of persons who, considered objectively, could turn against the organization at any time, can, through careful organization and backstopping, successfully prevent employees-cum-evildoers from taking the financial institution to the cleaners. This in itself is no mean task, but the reader is left wanting something more. Menendez’s prose does not lack for simplicity and accessibility, but the author’s achievement in clarity sacrifices character development and story. For example, Chapter 3, entitled “New Account Applications” in its opening sentence “The first line of defense against the abuse of our organization by money launderers is a careful investigation into the identity of the applicant” shows promise of meeting potential drug money launderers and riding shotgun with them on their daily collection routes, accompanying them to their rip-roaring drug parties with glittering supermodels and rapper icons, but fails to deliver even one marginally titillating moment. As like Chapters 1 and 2, Chapter 3 quickly devolves into mundane details about the contents of the account application form itself and checklists and punch sheets regarding the account opening process. Not one new character is introduced. There are no mysterious murders, no fifth column reporters, no conspiracy theory, no love. Menendez is no John Updike. While there are those who insist that he need not be; that such a comparison is patently unfair, please allow this critic to disagree. It was hoped, following his astonishing debut work, “Some Tips for How to Manage Accountants,” that this was a young author who had many promising years ahead. These hopes were confirmed by his next work, “Internal Audit Guidelines and Procedures”, which was filled with all of the exuberance of an aspiring accountant in love with his work and with life, and willing, on occasion, to take off his shoes and go wading through the babbling brook of daily human experience. In an interview at the time of publication, Menendez explained his life philosophy as “every day, I feel a little part of me die, but another part of me is born.” The characters in “Internal Audit Guidelines” showed how the author believed that life was more than just a constantly advancing conveyor belt down a long, narrow corridor to death. When “the manager” character, the presumptive hero (or heroine—Menendez’s characters are all asexual, throwing us off balance from the get go), engages the offshore entity balance sheet with his portable Sharp calculator, in a struggle that nearly ends in the destruction of the hero, the lesson is that somehow, each of us, has the potential to take hold of a part of life and reconcile it with someone else’s experience, making sure the numbers foot. Moreover, Menendez’s ground-breaking use of endnotes, rather than footnotes, took the concept of a “Guidelines” to the next level. It was, alas, a hope not to be realized. His next work, “Profits and Loss Columns”, took a step away from the edges of the abyss of personal human experience and brought the reader back to more mundane fundamentals of addition, and – more to the point – subtraction. The focus was on what was to be gained, and lost again, in a never-ending struggle for resolution of what at the end of the day, appeared, on its surface, to be insolvable. This critic, for one, found that model of life unsatisfying. Why must a victory inevitably mean a concomitant defeat? Why must a gain always be offset by a loss? Why couldn’t the forces of good outweigh the forces of bad? Wasn’t this more of a balance sheet approach to life? I, for one, had little stomach for it. And I told Menendez as much in my review of “Profits”. Hence, I was overjoyed to see he had taken my well-meaning criticism to heart when he followed “Profits” with “Balance Sheet Baby.” “Balance Sheet Baby” was his seminal work. In it, he brought forth all of the teaming angst that had been on the edges of his earlier works and, in this sly critique of off-balance sheet accounting and Sarbanes Oxley, summoned the wrath of the entire accountancy profession. His hero, Candice (Chad, after the sex change operation), was unflagging in her pursuit of the third party contracts and sale and lease back arrangements. When confronted by the aircraft engine leases, she stood her ground, even when the paralegal failed to show up. Time and time again in the course of the quarterly results teleconferences, Candice took no guff from the analysts and ultimately nearly lost an eye in a showdown with her CFO. It was, in its breadth and reach, in its understanding of the sinews and tendons of the corpus of financial accounting, a new height, a greater summit. Had it not been for the unfortunate S.E.C. summons and closed-door hearings subsequent to publication, I sincerely believe we would have seen more in the same vein from this promising young author.


Copyright 2009 Peter Swanger