DON'T LET YOUR COMPLIANCE OFFICERS WHO ARE BABY BOOMERS RETIRE; YOU NEED THEIR EXPERIENCE NOW MORE THAN EVER

A large contingent of the world's compliance officers, popularly known as Baby Boomers,  because they were born between 1946 and 1964, in the aftermath of the second World War, are reaching minimum  retirement age; many are choosing to retire. Unfortunately, this leaves many compliance departments without their most seasoned individuals, people who got into compliance right after 9-11, when the USA PATRIOT Act raised the bar in the banking industry, and resulted in a huge expansion of compliance staff at those of the world's banks which had substantial commerce with the American financial structure, which was just about every significant international institution.

These seasoned compliance veterans, who persevered through several phases and focuses of the compliance community, from terrorist financing fears, through major financial crime scandals, and international sanctions challenges regarding Iran, to the present day sanctions regime enacted in the aftermath of the Russian invasion of the Ukraine, have experienced a stream of professional challenges in their long careers. This baptism of fire has given them valuable skills which should continue to be of use in these troubled times.

One of the lessons that we learned from America's twenty-year war in Vietnam, and which I saw up close and personal, was that its most skilled and experienced combat troops rotated home after a year in-country, taking that knowledge, often earned the hard way, off the battlefield. This was a major tactical error; look at how, during the Second World War, this was not a policy. Difficult as it may be, you keep your experienced people on the line, and do not replace them with novices, if you want an effective force.

Your best compliance staff are standing down, and their replacements, with five years or less of frontline experience, are taking their place. In the world of compliance, frankly there is not substitute for time on the line. Encourage your retiring not to leave the field of AML/CFT battle, but to remain, even if it is on a reduced basis, for their battle-tested perspectives are a major asset to your compliance department. Give them some sort of senior status if you must, like elderly judges in the court system, cutting their hours and participation. Let them work remotely on enhanced due diligence investigations that they a more competent than their younger peers to handle. In short, keep them on the line, working your day-to-day compliance problems of 2023, as they are your best problem solvers. In this field, experience is the best teacher.* 

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* And definitely not your ineffective training programs given by bored and boring presenters with no background, which you are still giving to your new staff, but that's a subject for another day.