Brexit is a hard act to follow. After Britain upended the European Union, what in a column about regulatory compliance could possibly be worth reading?

That question occupied my mind for the better part of two weeks. I’d even taken to asking friends and family: “What would be worth reading in this circumstance?” It wasn’t until a family friend was picking up his daughter from the same event that something finally stuck.

I asked him for ideas. He replied without delay, “Write about not-Brexit.” And that got me thinking about not-CRS (Common Reporting Standards), and not-Fatca (Foreign Accounts Tax Compliance Act), etc.

Every month there is a new international emergency to write about but the local events are quiet.

Remember when the Organisation of Economic Cooperation and Development had us signing Tax Information Exchange Agreements (Tiea) with every vaguely-commercial way station around the globe?

Remember post-Panama Papers when the Premier signed an automatic information exchange about beneficial ownership with the UK?

And for every new initiative, project or treaty, there is a sudden and fortuitous growth in expertise. Within days, the financial-services community is beset with predictions of the dark days to come unless they seek out the all-knowing expert. He or she, who has been working on this initiative, project or treaty closely with the Bermuda Government, and therefore knows all there is to be known.

Then, as if turning the page in a novel you just can’t put down, another initiative, project or treaty comes from yet another international organisation or body. And wouldn’t you know it? That same expert about the last thing, is now an expert on this one too.

Meanwhile, back in the trenches, the work is piling up. The clients’ phone calls aren’t being answered in a timely fashion. The distributions or redemptions are being issued without the requisite checklists being completed. File reviews have taken a back seat. Staff haven’t been trained and no one has seen the policies and procedures manual since the last ‘expert’ blew through. There’s so many workarounds, no one is sure which one is the right way; or if there is one.

The management reports which are supposed to monitor all of this are left undone. The executives are rushing around getting ‘trained’ by ‘experts’ in the new ‘requirement’.

Unsurprisingly, the new requirement turns out to be little more than an underwhelming IT project dressed up with new regulatory terms.

Something far less interesting but far more relevant is the quiet news. For example, the amendment to Investment Funds Act 2006. In the year following a similar amendment to the Trusts (Regulation of Trust Business) Act 2001, a company paid $250,000 in fines. Unlike the anti-money laundering fines of $1.5 million in 2014, the trust fine didn’t take the regulator five years of supervision to work up to it. It happened before some were even aware the law changed.

No reason to put on a tuxedo but every reason to put on a helmet.

Long before the new requirements bite, the old ones will. And if this year’s annual report by the Bermuda Monetary Authority shows anything, it’s that some unfortunate people learnt that lesson last year.

I bet they had a bunch of Fatca training though.

Jarion Richardson, FICA, Certified Professional, CAMS, is the managing principal of Certainty, a compliance and regulatory consulting firm. He is a fellow of the International Compliance Association, Certified Anti-Money Laundering Specialist and formerly a Bermuda Monetary Authority examiner and Detective Constable in the Bermuda Police Service. He can be reached at www.certainty.bm.