IF YOU CANNOT BE EFFECTIVE AS A GATEKEEPER, DON'T BE A FRONTLINE COMPLIANCE OFFICER

I wonder how many bankers have heard of Albert vs. Association of Certified Anti-Money Specialists, 18-CV-05464 (ND GA), where a compliance officer sued, under Federal laws regarding the rights of the handicapped, regarding the conditions under which his examination for AML certification should be relaxed and modified for the plaintiff, who is learning-disabled. We are all aware that, at the university level, students with disabilities are given additional time to complete exams, and/or other benefits not available to others.

This is not a argument against such practises, which do effectively level the playing field, but the case involves a professional certificate, which could make the difference whether an individual is later hired, or not, as a compliance officer. My point is that compliance officer is a frontline, not support, position, where money launderers and financial criminals are constantly attempting to commit crimes through the bank, and not is up to the compliance officer, as the gatekeeper, to identify them in real-time, and interdict that dirty money, inn transit whenever possible. The job is not for anyone who is not at the top of their game, and is painfully aware that they work in an extremely time-sensitive environment, with little room for error. Speed of operation is a key element of compliance success; you've gotta be fast to meet deadlines.

If you don't have the best skills, and are always fast on the draw, you will probably miss that sole suspicious transaction, or transfer inconsistent with the client's trade or business, or obscure regulatory change, with the result that your bank or brokerage house passes a money laundering transaction, and faces possible civil penalties, negative publicity, or even a major regulatory hit. 

These frontline compliance positions are the combat roles, defending and protecting the bank's reputation, and sometimes even its future. They must be filled by the best, most competent people you can find, and anyone who might not be as sharp, represents a potential failure that doesn't have to happen. Put your best compliance people up front, please, and give support roles to those others who might not be, allowing them to provide valuable services in a secondary role. In the military, we call that combat support, and they are as necessary to your operation as frontline staff, but make sure you have everyone in compliance properly placed.