Monday, March 13, 2023


A good compliance leader knows how to seed his department with individuals who are not only competent in their jobs, but come from a variety of backgrounds where they learned skills which complement one another. If I had an unlimited budget, and I was a director of compliance at an international bank, I would populate my department with individuals having these categories of experience:

(1) Retired Federal law enforcement agents; many spend their entire 20-year careers investigating white collar crime, unscrambling difficult cases where their abilities are tested daily. That's the kind of compliance officer I want on my team.

(2) Veterans who are former Army intelligence officers: They are used to the application of analysis to unstructured data, and can easily transition over to AML/CFT work. Given the new emphasis on the examination of data gleaned by Artificial Intelligence platforms, their skills are welcome in conducting analysis of information. They are also used to working under pressure.

(3) Former police detectives; Those retired from white collar details are familiar with advanced investigative techniques, are used to working in stressful environments, and with time-sensitive projects. They may also have prior experience with AI programs, as law enforcement has been using them for several years now.

(4) Former laundryman: unfortunately, most money launderers that survive long enough to be incarcerated, quickly get out of the financial scene once they finish their sentences, and generally cannot be persuaded to consult with the legitimate private sector. the reason: some of their clients were never caught, and are now wealthy and perhaps even prominent, and might take offense if the man who could put them in prison was out there for the good guys.

Add individuals with the skill sets I have detailed above to a group of your traditional compliance officers, bank staff trained in-house and through outside programs, or former regulators, and hopefully an additional attorney who is genuinely interested in frontline compliance duties, and you have my "dream team," of people who could solve anything money launderers and financial criminals could throw at them. Think of individuals with these background when seeking to expand your compliance department; they can really elevate your level of compliance effectiveness.

No comments:

Post a Comment

Note: Only a member of this blog may post a comment.