SHOULD AMERICAN COMPLIANCE OFFICERS ORGANIZE AND JOIN A UNION?

                        

In the aftermath this week of America's Labor Day holiday, I am wondering whether it might be a smart move for compliance officers in the United States to seriously consider forming a union to protect their professional, as well as personal, rights. Over the years, I have observed that, since most compliance officers have no employment contract ( they are happy just be be employed) and therefore serve at the will of the bank where they toil, their job security is tenuous, at best. Allow me to bring up a few key points; before you object, go do your research. There are banks where the staff are unionized, and that arrangement doesn't seem to be a problem. Read on.

1. Zealous compliance officers doing their gatekeeper jobs are sometimes threatened with termination, when withdrawing an objection to account opening can later be considered by law enforcement to be Willful Blindness, which you should know ends up as a money laundering indictment against you, personally, while the New Accounts staff who forced you to back off is ignored. 

2. Union activity, which is protected by Federal law, gives compliance officers in different banks a legal excuse to talk or network with one another, whether that be to compare notes on software, discuss CIP and transaction monitoring policies & procedures, conduct professional education, and a larger number of topics while on the job. They would have a reason, outside of industry conferences, to contact one another.

3. A union could be a powerful advocate for establishing fair compensation in the industry, for assisting terminated compliance officers with employment issues, and for leveling what is currently an uneven playing field with regard to negotiating salary and benefits.

4. A bank whose executives are more concerned with maximizing profits would think twice before regularly overruling compliance onboarding decisions of their compliance officer, if he or she could then generally share dangerous bank policies with union leadership, which would educate its membership about the dangers of working there.

If this is this too adversarial a viewpoint, a union of compliance officers could set down industry employment guidelines, which the banks might be inclined to follow, if they wanted to attract talented and competent staff to their compliance department. Think about it.