WHO MAKES THE MOST EFFECTIVE COMPLIANCE DIRECTOR? THE ARGUMENT CONTINUES

Further to last week's discussion on the subject, from the Standard Chartered event: what background is preferable when choosing a director of global compliance? Everyone has an opinion, to be sure. My preference for a lawyer with significant compliance experience is no secret, but when it comes to the head position at an international financial institution, should we not look at alternatives?

Of course, retired law enforcement agents, who come from decades of transnational white collar crime investigations, and who have since been cross-trained to handle AML/CFT compliance from the banking and finance viewpoint also get my vote, as do former military intelligence officers with serious financial crime experience while in uniform. Both groups generally have significant leadership experience in supervision, analytic ability honed from multiple investigations, and a perspective which can be of immense benefit to compliance rank and file subordinates.

Unfortunately, those very few reformed money launderers available who might be convinced to become compliance officers most likely won't qualify, due to their criminal records, and the hesitancy of senior bank officials to hire them. Finally, we have the traditional staff compliance officer, with a general liberal arts or business administration background, who has distinguished himself or herself through years of successful frontline operation.

The best choice may be to onboard all the types of candidates within your compliance department, and with a satellite financial investigation unit, so as to reap the benefits of all the potential different individuals with the training and experience to identify active money laundering operations, in real time, and interdict them. What's your version of the answer?