While it's no secret thats stepping into departed New York Department of Financial Services Superintendent Ben Lawsky's shoes won't be an easy task, we know one thing about his replacement, Maria Vullo: She is clearly not afraid to engage that metaphor head-on.
Ms Vullo said on Wednesday that the previous superintendent had done “a terrific job. He put this agency on the map, big time.”
“I will not go easy on serious misconduct,” she added.
Even so, the former corporate lawyer told a New York audience: “I’m not Clint Eastwood. When they asked me if I’m the new sheriff I told them I don’t wear boots.”
Yeah, compliance officers, Maria don't wear no boots. And judging from the fact that she left her gig as a partner at Paul, Weiss to take the DFS job, we're gonna assume she wears expensive pumps or handmade sensible flats.
Sure, Ben Lawsky smacked Standard Chartered around like a rented mule, but did he do it in Louboutins? And Vullo is ready to talk more than just footwear.
Ms Vullo set out a shift in the department’s looming proposal on “transaction monitoring”, part of a wider push to change the culture of financial institutions to one of “true compliance”.
Under the plans, executives could be held responsible if their institutions fall foul of rules on terrorist financing, money laundering or other wrongdoing.
Jay Lippman, managing director at the consultancy Exiger, said there was “consternation” in the industry that regulators were targeting compliance officers.
On Wednesday Ms Vullo signalled that the department, which has held a consultation on the plans, would soften a standard of “strict liability” that it mooted in December.
However, she made clear that “there will be accountability at high levels”.
“Someone can’t just be like, ‘well I didn’t know about it’. Well, did you take the necessary actions to find out?”
Even without Lawsky and boots, the DFS is still not going to accept "Huh?" as a viable defense for financial wrongdoing. You've been warned.