Thursday, June 16, 2016


This poster, to entice Americans to enlist in NASA, for its upcoming push to not only explore Mars, in the coming decades, but to colonize it, could easily apply to compliance officers. What the financial community needs, most of all, are compliance officers who can discharge their duties with enthusiasm, and effectiveness.

What, in my humble opinion, makes a good compliance officer? here are my thoughts;

1. An effective compliance officer must be a renaissance man, or woman. This means a good liberal arts education, where they are exposed to not just history, geography, but language, technology, and yes, even literature, to be able to meet the challenges they face daily. Moving someone over from other divisions in the bank, to become a compliance officer, does not always work if they do not already have a well-rounded education as a foundation; they must be explorers of information.

2. A good compliance officer is not afraid to take on customer relationship/business development/ sales staff, when their need to new business is trumped by genuine compliance concerns.

3. He or she knows the tradecraft, the actual methods and tactics, of financial criminals, especially money launderers and fraudsters. if you don;t know how crime works, you cannot identify, and interdict it, in real time.

4. A effective compliance officer has a good relationship with both house counsel, and the outside attorneys who advise the bank. When potential compliance issues come up, a good lawyer on your side can make the difference between winning, and losing, your argument with senior bankers, who may be more intent on maximizing profits, at the expense of AML/CFT compliance.

5. Finally, a great compliance officer know where to go for reliable sources of non-public information, and never relies strictly upon commercial off-the-shelf data, when making major decisions.

Let's remember that an effective compliance officer never simply checks the box; he or she always looks further than the law, or best banking practices, requires, to get the answers;  Explore away.

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