Operational Risk Lessons to be leant (so many!!)
1. The problem arose, not because of the complex nature of the risks being taken in any new‐
fangled instruments, but from a straightforward failure of old‐fashioned internal controls.
The fact that Leeson was permitted throughout to remain in charge of both front office and
back office was a most serious failing.
2. Management failed to give due priority to their own internal auditors, who generally
performed well but whose comments were ignored. The Barings’ Group Treasurer had, in
February 1994, identified the dual role of Leeson (working in the front and back offices) as
unsatisfactory. Although the internal audits did not unearth the existence of the
unauthorised activities, the internal audit report did make specific recommendations as to
the separation of roles. These recommendations were never implemented; and at the local
operational level there seems to have taken no significant steps to give effect to the
recommended segregation of duties; even though in his management response to the report
the local manager had stated that with immediate effect (1994) Leeson would cease to
perform certain functions and that he would ensure the adequate supervision of all
settlement and recording processes. The subsequent Bank of England report considered that
this failure to put into effect his management response to these recommendations in the
internal audit reports was reprehensible.
3. In addition, Coppers & Lybrand, the external auditors, came in for severe criticism in the
official report, especially over their 1994 conclusion that the internal controls were
satisfactory. This observation is not easy to reconcile with the transparent lack of
segregation of duties as well as other glaring shortcomings within the Singapore
subsidiary. (As an aside, it transpired that a fax, supposedly confirming a vital transaction
but later found to be a forgery, was found in the Coopers & Lybrand audit files in Singapore.
It contained the header “From Nick and Lisa”!!)