Member Spotlight: For Muhammad Rizwan Khan, true compliance a balance of learning, teaching
Thursday, October 12, 2017
Posted by: Brian Monroe
By Brian Monroe
October 12, 2017
For Muhammad Rizwan Khan, the journey to becoming a professional in the field of financial crime compliance started with a simple, but profound, idea more than two decades ago: How can I help prevent people’s lives from being impacted by criminal and terror groups.
That desire to help others while sharing knowledge on how best to implement best practices to detect and prevent all financial crimes – and turn small opportunities for learning into big chances for growth – has culminated in his current position as Chief Compliance Officer for Dubai-based Premier International Exchange, which provides remittance, foreign exchange and payment services to customers in the United Arab Emirates.
The native of Pakistan truly believes that in order to be a professional who makes a difference in the lives of strangers, in his job and his field, anti-money laundering (AML) officers must work in true partnership with the business lines, not at odds with them, in a system where profits don’t overshadow proper controls, and the generators of a firm’s revenue also value compliance input and insight.
“I want, in whatever small way that I am able, to help to prevent peoples’ lives from being negatively impacted by financial crime or the effects of terrorism,” he told ACFCS. “Financial crime, unfortunately, seems ubiquitous, and its effects are devastating. Whether it is a single-family member stealing from a vulnerable individual or a network committing fraud against government welfare programs, there are individuals whose lives will be made more difficult because of the misuse of those resources.”
But that passion to do good is paired with a positive outlook and humbleness to appreciate, and seize, seemingly smaller opportunities to learn that could yield big dividends later, depending on how you view the situation.
“There is always a big opportunity hidden in small opportunities and we need to explore that opportunity,” he wrote. “Only then, this small opportunity becomes the big one. But that all depends on what is your vision and mission. If we think small, we become small. If we think big, we become big. So, your objective should always be big and your effort should always be maximum.”
Prior to his current position, Khan was a compliance manager for the Economic Exchange Centre in Dubai, where he worked with the company and regulators to implement financial crime compliance objectives across the institution, including ensuring business units are compliant. He also has a Masters Degree in Business Administration.
Khan has also been voracious in his desire to add to his skillset, racking up in recent years an impressive array of certifications in the areas of financial crime compliance, finance and cybersecurity, including the CFCS designation, which he called a “unique platform to establish the core professionalism and competence in the area of financial crimes.”
The concepts he has learned in studying for the certification provide “real direction to the AML and Anti-Financial Crime communities to create and establish proper controls to mitigate the risk of different challenges.”
The achievements have quickly aided him in making immediate improvements in his job, helping to better organize certain aspects of the compliance program, better understand investigations and escalate and construct reports of suspicious activity, he said.
Here are some of his thoughts in our latest ACFCS Member Spotlight:
What do you do in your current role?
I am the Chief Compliance Officer of “Premier International Exchange” and am responsible for all of the compliance department, including KYC procedures, Customer Due Diligence (CDD), the Transaction Monitoring System, STRs detailing escalation and mitigation factors, Enhanced Due Diligence (EDD) reviews including behavioral analysis, Trade Price Manipulation analysis and Regulatory laws and regulations implementation.
I believe in implementing stringent compliance controls in the company, as we understand there is a very thin line separating compliance and business. Compliance should not overcome business, while at the same time, business should also not overshadow the compliance function.
The approach of compliance should be very effective, balanced and proportionate. But, overall, there can be no compromising on compliance because breaching can escalate regulatory risk.
What does your career trajectory in financial crime look like?
There is big challenge of Money Laundering around the world and launderers are adopting different trends and typologies to avoid the detection. First, I decided to take anti-money laundering (AML) training and passed the CAMS examination.
But actually, I thought it was very important to know all the predicate crimes of money laundering more in-depth, therefore I took the ACFCS course to achieve the CFCS certification. One reason I chose the designation is that it covered all financial crimes, including cybercrimes.
Typically, the courses of other association programs focus on only a piece of financial crime. But CFCS is a more organized and practical course which covered all the areas of financial crimes. Now, since I am CFCS-qualified, I have full competence to meet the current reality of financial crime challenges. Studying for the ACFCS certification was also very helpful in giving me more awareness about more crimes, scenarios and situations that happen on a daily basis.
One part of CFCS certification, covering data protection and cybercrimes, also inclined me and inspired me to do more work in this area. As a result, I also achieved the milestone of becoming a Certified Cyber Intelligence Professional (CCIP).
What is the best advice you’ve ever received?
There is always a big opportunity hidden in small opportunities and we need to explore that opportunity. Only then, this small opportunity becomes the big one. But that all depends on what is your vision and mission. If we think small, we become small. If we think big, we become big. So, your objective should always be big and your effort should always be maximum.
What is the worst advice you’ve ever received?
The worst advise is very funny. When I started my career 24 years ago, one of my supervisors told me to never accept your mistakes. So, sometimes, it makes me laugh and yes, it’s a world where we meet different types of people.
What would you say are the most important attributes for someone in your role to be able to succeed?
Actually, when we work in a bank or exchange house, our business mostly derives from our correspondent bank relationships. And especially since 9/11, we are cognizant one of the biggest reasons behind the funding of terrorism was the misuse of correspondent banks.
Many transactions were executed without stringent compliance from high risk jurisdictions. So, I as a CFCS-certified member, think we can mitigate the risk of these types of activities if we are well educated in combating financial crimes.
I can say the ACFCS platform explored new areas of financial crime and expanded my skills more and more. Now we have a very stringent compliance department more able to combat all the challenges inherent in correspondent arrangements.
How has (compliance, investigations, etc.) changed and evolved during your career?
I think that the compliance challenges on day-to-day basis always gives new opportunities for learning. That is the beauty of this program, because on this journey I also realized how to better handle regulatory queries, which makes your business and company safer from incurring any regulatory penalties from breaching a compliance compact.
Even earlier in my career, I was not very much equipped to deal with cyber challenges. But as I got more understanding about this field, studying the CFCS manual, I became more aware of the challenges of hacking, account takeover, vishing, smising, spear fishing, etc. That piqued my interest and forced me to update myself and my knowledge base with new skills.
What do you see as key challenges related to financial crime in your role or in the sector overall?
Third-party transactions are one of the big challenges in our industry. That’s because if the model of compliance is not properly established to cover the risk of third parties, it will be great trouble for the company.
Anonymity in third-party transactions is also a big issue. It is important to understand the risk assessment model of the company, how to determine the ultimate ordering customer, ordering customer, beneficiary, ultimate beneficiary and role of the middle agent.
There are so many areas where vulnerabilities arise in determining the entities involved in third-party transactions. These are not supposed to be illegitimate, but there should be proper connectivity to document who is involved and how before executing such transactions.
What motivated you to become a financial crime professional?
I want, in whatever small way that I am able, to help to prevent peoples’ lives from being negatively impacted by financial crime or the effects of terrorism. Financial crime, unfortunately, seems ubiquitous, and its effects are devastating.
Whether it is a single-family member stealing from a vulnerable individual or a network committing fraud against government welfare programs, there are individuals whose lives will be made more difficult because of the misuse of those resources.
Is there anything that surprised you about your current role?
Some challenges, like during interviewing employees’ investigations, some facts which we got to know were very surprising, especially related to weakness of internal controls. That surprised me a lot. Then we got to know the importance of anonymous reporting and we established a whistleblower system to give the complete freedom of opinion to staff for unexpected events.
Why did you join ACFCS and/or become CFCS certified?
ACFCS is the only platform that provides an excellent opportunity to enhance your professional skills and competence in all areas of financial crime. The most attractive thing in this course is that it maintains confidentiality, integrity and honesty.
The real-life cases and scenario-based questions are very much professionally established and the CFCS manual is very informative, covering all the areas of financial crimes. Awareness for international standards like FATF, FATCA, FCPA, and the UK bribery act are stated in a very comprehensive manner.
ACFCS is a combination of anti-money laundering/terrorism and all financial crimes, so the horizon is broader than the other conventional programs, so there is very much a broader scope of learning.
As well, the online webinars and compliance reports related to recent advancements in the compliance and financial crime worlds is amazing.
It is more demanding in the industry and being CFCS-qualified means compliance professionals potentially can have bigger status in their organization and salaries in their profession. Due to the training, content and offerings at ACFCS, there is proper guidance available for MSBs and banks.
What is the most rewarding part of your job?
The most interesting and rewarding part of my job is the ongoing learning process. It is not just sticking to only one task. My role in the compliance department is parallel to my education and now I have practical exposure to implement all those points which I have studied.