CC-101 · Lesson 2 · It is the service, not the job title

The people who get missed

Most programs cover the sales team well. The gaps are almost always somewhere quieter — and that is where a first impression of a customer gets formed.

23 September 2026 · Amanda Dunn · 4 min read

If a firm gets one thing right early, it is training the agents who sign up sellers and deal with buyers. Fair enough — that is where the obvious exposure sits.

The gaps are reliably elsewhere, and they are worth walking through deliberately.

The first contact

Someone answers the phone, or the enquiry form, or the door on a Saturday. They are often the least trained person in the building and the first to hear something odd — a caller who will not give a name, a buyer asking unusual questions about how payment could be structured.

They do not need to diagnose anything. They need to know that "that was strange" is worth passing on, and who to pass it to.

The person doing the paperwork

Administrators and contract staff see identity documents, ownership structures and payment arrangements in one place more often than anyone else. If something does not reconcile, they are usually the ones positioned to notice — and often the least likely to think it is their place to say so.

Tell your admin team explicitly that noticing is part of their job. Otherwise they will assume that someone more senior has already thought about it. Frequently nobody has.

The principal

In a small firm the owner is often the busiest person and the least trained, because training is something you organise for staff. They are also frequently the governing body for AML/CTF purposes, the person who receives the annual compliance report, and the one accountable if things go wrong.

Everyone who covers for someone

Programs are written around normal weeks. Real weeks have illness, leave and someone stepping in. If the only person who knows how to escalate is the one on annual leave, the process does not exist that fortnight.

The fix costs nothing: name a backup, write the name down, and make sure the team knows it.

Notice and escalate. Do not decide. →Why the judgement call deliberately is not yours to make.

Where Curlew fits

Curlew holds the team list, the roles, the designated compliance officer as a named individual, and the personnel due diligence and training records against each person. So the question "who is trained, on what, and when did they last do it?" is answerable from a screen rather than reconstructed from memory.

The training itself is your call. Keeping the evidence of it is the part we take off you.