[Rewind 2020] How to be a better financial crime professional in 2021? - Part 1 - Learning
In the beginning of 2021, we prepared our first rewind episode featuring all the great advices and recommendations of our last year guests on how to be a better financial crime professional. We know you may have been too busy to listen to the whole episode, so here we summarized all the highlights.
Now you can read about how to prepare for a career or promotion in compliance, the importance of learning and technology, how to understand risks and regulations. The links you would find through the text are leading to the specific episodes quoted in case you’d like to check them out in full.
As Jennifer Ford-Smith said, “You are not in this field if you are going to glaze over, you need to be detail oriented and really wanting to pursue something until you find out, and solve that puzzle”.
So let’s start with the summary of what a job in compliance mean, what are the challenges and how to overcome them by Sujata Dasgupta.
“Compliance, I think, is a very very though job because the regulations have been very dynamic and what I have been seeing, like I said I have more than 20 years of experience now, and I have worked across geographies, it has been so dynamic in the past 8 to 10 years, the changes that I have seen in this last decade is not something I have seen in the decade before that.
Definitely what we see is the pace of change of the regulation now is extremely rapid, very dynamic and for compliance professionals, for them it's so important to be aware, completely knowledgeable of all the regulations of all the changes, the various jurisdictions they are looking after, the various customer segments they are looking after. They have to be completely thorough because if they miss something, that would result in penalty for the banks or even personal liability for the professionals themselves. It's an extremely tough job, very sensitive function and the problem is because of change of regulations, banks also have to make a lot of changes to their systems, to their processes. So what happens is, it is ultimately the compliance professionals who are at the first or the second line of defense, have to lift all this on their shoulders to prevent the bank from being into any penalties.
Other challenges of compliance is that it's largely a manual functions. It involves a lot of data collection and analysis, and most of the times this data does not reside in one system - you have to go and collect it from multiple different systems. The manual effort in work is huge and on the other hand, you have to adhere to all these SLAs as well. So the dilemma becomes whether it has to be an effective or an efficient compliance activity, because effectiveness means you have to give it a lot of time, a lot of in depth analysis. Whereas efficient means you have to complete everything within the given SLA which sometimes becomes very though for the compliance professional. So it becomes a dilemma between effectiveness vs efficiency.”
But there were also some good news from Sujata, as though there are a lot of challenges still, the future looks bright.
“We are seeing a lot of adoption of advanced technologies and digitalization.
There is an increasing adoption in the area of compliance and over the past at least 3 to 4 years we are seeing that banks are increasingly implementing a lot of advanced technologies and most of these are being used for data collection and the aggregation of data so that compliance professionals do not have to focus a lot of time and energy on collection of data. At least that part is being taken care of by the technology advancement. Of course, a lot of their time would get freed up. So, we were discussing a lot of manual effort involves a lot of time, so in the near future I see that that effort would definitely get reduced. That would give them a lot of time to enrich their skills.
Firstly, make yourselves aware of what are the regulations, what are the processes, the rules and technology that are used by your organization. If you are working in a certain organization, you need to be fully aware of what the regulations you need to follow according to your jurisdiction and the jurisdiction that you are looking at. Also, the internal processes that are defined by your second line of defense whether you are following all those processes, what are those processes. Sometimes what happens is you are so stressed out doing your daily job, you may not be aware that there has been a change to a certain process and that you need to adjust your actions accordingly. Further, what are the tools that are being used? As a user what are the tools that you should be using? If you don't know how to use that tool you have to focus and enrich your skills in using those tools and solutions.
That is about the awareness in terms of the internal environment, within your organization. As compliance professionals we also need to be updated as to what the industry best practices are. Financial crimes compliance has standard industry best practices which are being prevalent across most jurisdictions and are common. Thus, a knowledge of industry best practices, the trends, what are the new initiatives, what other general problems that banks are facing and what are they doing to resolve those problems.
Thirdly, I would say because a lot of these manual activities are getting digitized and automated, a lot of these data collection activities will soon go away and a new set of skills will be required. Because now the professionals would be focusing more in decisions on whatever results were being thrown up by these advanced solutions, we have seen that there's a lot of data visualization and graphs, and all of this data output that comes out. Compliance professionals should be skilled enough to make sense what these mean, how to analyze all these data, how to take decision on these visualizations and graphs that are generated by the AI based solutions. These are some of the analytical skills and data related skills which they need to certainly upgrade on in terms of being able to do their job better in the near future.”
Considering all the challenges and future of compliance, how do you know if this career is good for you? How to select your path? In episode one Jennifer Ford-Smith told us.
“I think it isn't like becoming a doctor where there're many pre-described fields with some that are new and emerging.
Financial crime and compliance evolves, it evolves as technology evolves and we get new ways of providing financing but also it evolves as regulations change. So, there are great study materials online but because the field is so broad, a great place to start is to see what aspects of the financial crime field is of interest. Some people love the policy side of compliance, and we need these people to ensure rigor and fairness in the system. Those people tend to be very organized, they really like seeing the solution and coming to it quickly. Others may gravitate to money laundering investigations at a transaction level at a bank. Others may enjoy corporate security investigation or those requiring a lot of interviewing and one-on-one interviewing styles. Looking at something at a transaction level can be for somebody who is more on the analyzing data type of skills there.
And you really don't know until you try, so whether it's pursuing financial crime, fraud or money laundering certification, that can be a good place to start if somebody doesn't have practice on the street or in the field. Of course, job shadowing, or reaching out to somebody for a coffee and you just ask what they love and see what's interesting and try your best to read up on it.”
There is one commonality connecting all different compliance professions – no matter what you do, you will have to continuously, tirelessly, proactively learn throughout your whole career.
While talking to Teresa Anaya about the cryptocurrency certification course, she highlighted the importance of learning in the field and why you can’t get by without stepping out of your comfort zone.
“Something that people may not realize is that the learning from this course forces someone out of their comfort zone. And it may be uncomfortable but it conditions someone to be comfortable with the unknown and that's really hard. It's been really hard for me even though I am someone who really likes to learn. There's still so much to learn in the space, and there're times where I'm like “I'm just not getting it”, but I keep at it and I am learning to be comfortable not knowing and trying to get there. I think there are a lot of people in the financial crime and compliance space, they are analyst that are at large banks and they get pigeonholed into doing the same thing over and over again, and there's large portion of them who'll get frustrated by that, who want to move on, who want to learn a new skillset. And I've been in that position too. I would say you're going to have to take it upon yourself to go and try to learn these things.”
The financial crime environment is very dynamic. So, we know that learning is important. Dr. Ian Messenger gave us two perspectives as to why learning is crucial both personally and professionally.
“Learning is really important for compliance officers, both personally and professionally. And I think it's important to separate the two. From a professional perspective, the methods and techniques by criminals used in terror financers are constantly evolving and they are always one step ahead of both law enforcement and also the private sector. Keeping up to date on current policies, current trends is crucial for an effective compliance officer.
Also, if we look at what compliance is, there was historically position that compliance meant AML, whereas from my perspective and from my observations compliance is multifaceted. We have AML, we have fraud, we have sanctions, and each of those aspects have their own nuances, have their own specialisms and their own quirks. Thus, a well-rounded compliance officers have to have really strong understanding of all of these aspects. Especially because the role of the compliance officer is changing in many financial institutions.
Historically we saw both in financial institutions and the public sector, a very siloed approach. You would have individuals working in AML, individuals working in fraud, individuals working in sanctions and they would very much work independently.
I've observed over the past several years there's a convergence of these roles. There're no longer separate departments, it's a combined compliance function.
Also from a personal perspective, in order to keep yourself relevant and competitive in the labor market, it's important to have that constant learning mindset.”
One of the sources from which compliance professionals learn from is the news. You can learn about fines, recent penalties, new tactics employed by fraudsters and criminals, geographies and events having impact on the way money are laundered and so much more. In 2020, one of our guests was Dev Odedra. He is the founder of the AML news aggregator, The Laundry. See Dev’s advice on why you should be proactive and what the benefits of reading all the top news are.
“It's easy to know what's required from a regulator but do professionals understand the money laundering element and the financial crime element of their job? Knowing, I think, is not enough. I think we need to understand.
We can know something and we can recite it but do we understand what we say we know or what we think we know. And I think that's how we can maybe reduce the risk or stop the risk of financial crime, is by actually understanding the issue, the goings on in the field and really seeing the whole picture in order to help in our jobs on day to day basis.
You can have an analyst who's looking at something and it all might look OK but they've might read an article that includes a certain typology or trend that's not in any regulatory report, that's not in any guidance documents, that might help them do their job better. They might spot something that they might have missed and had they not known about it from that general reading and keeping up to date with their awareness of our field.
The landscape in financial crime is moving fast both from regulatory perspective but even from the criminal element too. So I'd just say just keep up to date with what's going on.
Don't just wait for new regulation or new guidance to come out. Try and think for yourself. Think about what's happening in our industry, in our field if you will, what are the bad guys doing around the world, not just locally. And try and make your own decisions, build your own thoughts and just never stop looking at what's happening in our field. It's ever evolving.
Stephen Scott also mentioned about learning, getting used to the language and terminology, thinking like a criminal and how all this would help.
“Don't think like a policeman, think like a criminal and translate that into learning the terms that they use in the drug world, the human trafficking world and in the fraud world.
There will be notes and people will have conversations with you or send messages to each other when they conduct transactions online. Key words will be included in the comment section of a new transfer. It may say "rent" in a normal transaction but it might say “green” or “white” on a drug transaction. Green being marijuana and white being cocaine. Or may be “soft” or “hard” you might see that one and soft being cocaine, hard being crack cocaine.
In terms of just plain compliance, we talk about know your customer but going back to John Groom and his six stages, he also talks about knowing the economic unit. Get to know who your client's families are, who their close associates are. This fits into the PEP world right away. If you want to find their assets - look for the kids. They are stealing the money in order to create a legacy for their family, for when they are out powered, when they get killed or simply voted out of office. They'll put the assets in their kids’ names. So, it's thinking like a bad guy in terms of
“How would I hide my money? Where I'd hide my money? Who I would trust to move my money?”.
In many of these countries money are stolen from is going a lot to a safe havens like New York, London, Vancouver, Singapore, and it's not going to stay in the countries where these guys live because ultimately it's going to be or potentially seized in these countries pursuant to their legislation. So to me, learning the family, knowing your business or the economic unit, it is continuous learning, and it means going out to the FATF sites, or RUSI, following up on LinkedIn when somebody posts something.
It's kind of that simple to me, it's time, learning, having an interest, reading. Don't just make it a 9 to 5 job in some ways because the policemen, men and women, sure don't, it's 24/7 for most of us that deal with this."
Part 2 of this blog - Technology and Risk will be published next week. If you cannot wait, hear the full podcast episode on you favorite podcast platform or on our website.
To be continued...