No matter how many years – decades, now! – I’ve lived in Russia, clearing Customs (passport control) for me, as a foreigner, is at best a destabilizing experience.  Russians are not a howdee-big-smile sort of people to begin with; and Russian Customs Officials are trained to look at you and your documents in a manner calculated to convey that something here is seriously amiss.  Your papers are not in order.  No entry.  Please step aside and wait to be escorted to a small, sparse holding area while we arrange for your return to your point of origin – never again to be granted an entry visa to the Motherland.

And then it happened … as always, when you are the most vulnerable and least expecting it.  I had taken a late-day flight back to Moscow from London; it was timed to arrive shortly before 11.00 p.m., so there’d be little if any traffic for my driver to cut through on the long, straight shot from Sheremetyevo Airport to my home on Prospekt Mira.

I was tired; I had stayed too long at a banking conference in London’s City Centre, and had left too little time for commuting to Heathrow.  Stepping into the passport control booth in Moscow, an especially dour male of the species glared at me as I produced my passport.  After several minutes of silence, I was waiting for the heavy, triple ka-thunk of the douanier’s entry stamp landing on my passport and migration card.  Nothing.  Silencio.  And then his head rears up abruptly and a stern face announces those fateful words: ‘Your papers are not in order.’  What?  Why?  How not in order?  A true professional, he allowed all those thoughts and emotions to register on my face, followed by my anticipation of the inevitable, life altering refrain: ‘Please step aside.’

But this mini-opera has no such refrain.  Instead, my largish Russian Customs official with gravity-bound jowls holds up my passport like the murder weapon in an Agatha Christie mystery, and he solemnly announces his verdict with a silly, gotcha grin: ‘Your passport’s eagle has only one head.’  Tee-hee-hee, ho-ho, that was a good one.  Yes, sir, you sure got me good.  Inspired … just brilliant.  Thank you.  OK, let’s see whether my heart attack happens before or after my luggage appears at the carousel.

russian passport

Just like the eagle on a Russian passport, January is the month that casts its gaze both backward and forward … a time for retrospection and anticipation; for drawing conclusions and drafting projections.  Did financial regulatory Compliance evolve in 2013?  If so, how?  And what is 2014 likely to hold in store for those of us who dare look forward?  What changes are we likely to see, and why?

Let’s take a quick mental leap back to the gateway to 2013.  We have just rounded out the year that was supposed to have been the financial regulator’s apotheosis:  A Wagnerian finale, with the gods entering their mega-regulatory Valhalla of a new world order.  By the time the regulatory chorus and orchestra reached 31 December 2013, ‘hosannahs!’ should have been heard from the rafters of the opera theatre, and bouquets of roses should have been arcing o’er the orchestra pit and bouncing off the heavy curtains.

Well?  Has the zaftig lady sung yet?  Not quite.  In fact, she’s still backstage in her bathrobe and slippers awaiting her stage call.  Remember the critically acclaimed Volcker aria?  It’s suddenly been re-billed as the Volcker Unfinished Symphony.

FATCA?   FATCA was billed as one of the dangerous immortals from the Wagnerian Ring’s Underworld.  Well, FATCA has been demoted to a cuckolded basso buffo from a Rossini comedy.   (Ouch!)   FATCA is now the name of the ‘chaotic chorus’ scene, where everyone sings his or her own part, but somehow it all holds together like a caricature of a Bach contraption.


*The author’s views and opinions are entirely his or her own and may not reflect the views and opinions of 360factors.