Thursday, March 30, 2023


We noted a lengthy article yesterday extolling the virtues of certain unnamed European compliance officers for duty in the Middle East, and we wondered aloud just how many of those esteemed candidates actually read and speak Arabic as that is the principal lingua franca of the region. The use of generic compliance officers, not coming from the region in which they are seconded, while perhaps appearing appropriate, often results in ineffective individuals whose cultural illiteracy in the region causes them to fail at their jobs.

Remember, compliance officers must be knowledgeable about culture, history, language and business practices where they are working, and a monolingual compliance officer from Western Europe will miss more than he or she catches, regarding complex money laundering schemes that exploit loopholes in local laws, or in commercial operations. Unless your foreign compliance officer is truly an Arabist, with personal educational or vocational experience in the region, laundrymen will most likely run rings around him until he gets the lay of the land, if that even ever happens. Also, how will that individual be able to utilize the new advantages that advances in artificial intelligence offer if monolingual?

While there are some individuals who have the background to be transplanted halfway around the world to discharge serious compliance responsibilities, they are unfortunately few in number. Selecting locally-trained, educated and raised talent is generally the only effective choice that bank management should make. Give that well-qualified candidate a pass, in favor of those home-grown and locally educated individuals who may not have the stellar credentials of those from Europe or North America, but who will not fail due to cultural ignorance and unfamiliarity.

Money launderers and financial criminals make it their business to know precisely who is in command in compliance departments at international banks, as well as frontline staff, because I know I did that back in the day. Place locally savvy talent in those positions if you want to both deter as well as interdict the laundrymen, in real-time, consistently and effectively.

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