• Being successful in the field of financial crime compliance is difficult in the best of times – but in the last year or so, those challenges have risen dramatically as individuals, teams and entire market sectors in the private and private spaces have dealt with a historic degree of disruption.
• Some examples: the rising need for a diverse skillset to see and report on the full spectrum of financial crime, more focus on technologies like artificial intelligence and automation, increasingly crafty and creative criminals attacking institutions using cyber-enabled frauds – and let’s not forget a global pandemic upending every aspect of your professional and personal lives.
• More than straight job skills or a seemingly glowing resume with the requisite experience, fincrime compliance leaders are looking for professionals with a passion and fearlessness to learn, a warmth and willingness to capture and share knowledge and curiosity and charisma to grow – and get others in and out of compliance to believe in their cause and support them.
• Those are just some of the tips, tactics and practical takeaways from ACFCS’ Back to the Future of Fincrime Virtual Conference, that took place in late January, with more than 4,300 fincrime professionals attending, including compliance officers, regulators, investigators and top industry watchdog and banking lobbying groups.

By Brian Monroe
bmonroe@acfcs.org
February 5, 2021

Being successful in the field of financial crime compliance is difficult in the best of times – but in the last year or so, those challenges have risen dramatically as individuals, teams and entire market sectors in the public and private spaces have dealt with a historic degree of disruption.

Some examples: the rising need for a diverse skillset to see and report on the full spectrum of financial crime, more focus on technologies like artificial intelligence and automation, increasingly crafty and creative criminals attacking institutions using cyber-enabled frauds – and let’s not forget a global pandemic upending every aspect of your professional and personal lives.

That likely won’t change any time soon with the recent passage of the Anti-Money Laundering Act (AMLA) in the United States through Congress, which is designed to break open beneficial ownership bastions and bolster information to and sharing between law enforcement and industry – a monumental change some say is as transformative as the 2001 U.S.A Patriot Act.

That is interwoven and underpinned by incoming changes in an advanced notice of proposed rulemaking by the U.S. Treasury’s Financial Crimes Enforcement (FinCEN) to turn the entire compliance field on its head, shifting from a focus on rote regulatory compliance tasks to “effective” AML programs creating intelligence with a “high degree of usefulness to law enforcement.”

So it might not be as surprising to find out that many current and former chief compliance and anti-money laundering (AML) officers have stated they value, in some cases, the softer skills when hiring outsiders or promoting from within.

What does that mean?

More than straight job skills or a seemingly glowing resume with the requisite experience, fincrime compliance leaders are looking for professionals with a passion and fearlessness to learn, a warmth and willingness to capture and share knowledge and curiosity and charisma to grow – and get others in and out of compliance to believe in their cause and support them.

Those are just some of the tips, tactics and practical takeaways from ACFCS’ Back to the Future of Fincrime Virtual Conference, that took place in late January, with more than 4,300 fincrime professionals attending, including compliance officers, regulators, investigators and top industry watchdog and banking lobbying groups.

The final day of the conference was focused on the future of fincrime job skills.

Some of the soft skills that are valued and will help professionals rise into upper echelon compliance positions, according to Eric Young, the former Chief Compliance Officer at BNP Paribas, include being:

• Calm: Compliance can be stressful. So top officers must be a source of inspiration, an oasis of strength even in regulatory storms, deadlines and exams.
• Credible: Knowledge is power, but critical compliance decisions must be spurred by insight, analysis and experience. Your team must believe in you to fight the good fight for you.
• Confident: At a large institution, compliance teams can be vast, numbering hundreds of people. That is why they look to, and need, leaders who are respected, and respect others, and move compliance initiatives forward with the trust of their team.  
• Clear: In direction and always during a crisis. Time management, communication and coordination with internal teams, budget overlords, external examiners and even law enforcement is all part of the drill for a compliance leader. So communicating and elucidating with clarity of mission objectives is of paramount importance.
• Courageous: You have to have the backbone to say no to the business line and make difficult decisions.

But there are some critical considerations job seekers must also weigh, which can have major repercussions on career advancement and even fueling the passion-purpose feedback loop that is vital for success in any position and getting the attention of others to help guide you, said Sonia Desai, the AML/BSA Officer for Revolut.

The questions someone should ask?

• Is it a company you believe in?
• Is it a boss you can learn from?
• Is it a role you can make a difference?

“If you do a good job, the mentors will find you,” Desai said.  

As well, what steps should a fincrime compliance professional take to rise in their career and build experience to get that dream job?

Try starting at your current job first, she said.  

Quick recap of the compliance job market: ups, downs, but surge incoming?

Excellent experience and strong soft skills are important for any job seeker, but have become more heavily scrutinized in fincrime compliance in recent years as banks have been more choosy with entry level positions and expensive, senior-level spots.

At the tail end of 2000s, the AML job market weakened due to the still lingering financial crisis and mortgage meltdown.

The market, however, rebounded and surged between 2012 and 2016, with a softening during the pandemic as overall world economic throughput plummeted and banks tightened their belt, in many cases halting hiring and in some scenarios trimming staff, including compliance positions.

“In April, the shocking estimate of $181 billion was the number forecast by LexisNexis Risk Solutions to cover the costs of compliance by financial firms globally with an average spend of $10,000 per employee. The Dodd-Frank Act of 2010 alone spiked compliance costs by $50 billion per annum; how high is the COVID spike going to be?” according to an article titled “Covid and the compliance job market.”

The piece noted that trying to cut compliance costs and focus on profits can have long term expensive consequences, particularly after a time of economic constriction when regulators and investigators have a chance to really dig in and scrutinize counter-crime programs that have been left to wither on the vine.

“Reduce compliance spending, you say? Not a good idea: costs nearly triple (2.71x) for firms who cut corners, don’t comply and get caught,” according to the article. “Banks paid $321 billion on settlement fines and other enforcement actions 2008-2018 in the backlash to the financial crisis.”  

But the trepidation to boost compliance spending during the COVID-19 pandemic could be changing under a new administration, say some compliance recruiters.

There also could be more opportunities on the horizon because “Democrats in the White House are typically good for compliance jobs,” said Zachary Plotkin, head of the Compliance, Legal & Privacy/Cyber Risk/GDPR/CCPA Practice Area and staffing expert at Infinity Consulting Solutions.

But to get a job, you must also get yourself on the radar of potential employees, even though, admittedly, not everyone is a savvy networker or social butterfly.

But many speakers during ACFCS’ Career Day focused on the ‘Future of Fincrime Skills’ have exhorted more shy professionals to come out of their shells and network, particularly now.

Why?

Roughly “90 percent of getting a job is who you know. The other 10 percent is timing. It’s about putting yourself out there.”

Back to the Future of Fincrime Conference Snapshot: practical, real world responses

Day Four of the ACFCS virtual summit focused on tips and tactics to break into and rise in the fincrime compliance field, while prior days tackled historical and emerging challenges, real world cases and threat actor red flags and risks and responses to attacks in the real and virtual worlds.

Day Three of ACFCS’ Back to the Future of Financial started with a dive into digital worlds and a look at the connections between the volatile virtual value sector, cyber hack attacks, like ransomware fusillades, and the darknet markets fueling organized criminal groups and low-ranking illicit opportunists alike.

In all, an appropriate foray with the day’s theme being “The Future of Fincrime Threats.” To read the full story, click here.

Day Two of the summit touched on technology, the need for human expertise and continued calls for convergence between fincrime compliance departments, such as AML, fraud and cybersecurity in a bid to bolster resources, firm up effectiveness and create better, more detailed reports for investigators.

Top minds from the financial crime and compliance field offered insight, guidance and tips on historical and emerging threat vectors, including the billions of dollars in fraud tied to the U.S. government’s Paycheck Protection Program, the nuanced transaction trails of human traffickers, the power and promise of AI and the risks, rancor and resources needed to bolster crypto compliance.

To read the full story, click here.

Day One of ACFCS’ Back to the Future of Fincrime Virtual Summit saw speakers cover the nexus between crypto value and terror groups, upcoming changes to the U.S. financial crime compliance and sanctions regimes, the power of breaking down corporate opacity barriers, cyberattack and defense strategies and more.

To read the full story, click here.

AML job market could get supercharged by new Congressional mandates, incoming rules

The disruption of the fincrime compliance job market is likely to rumble further into 2021 as new and updated U.S. countercrime rules formalize, along with similar updates in the European Union under their latest AML directive.

In the U.S., the centerpiece of the country’s efforts comes in the form of the recently passed Anti-Money Laundering Act (AMLA), what many are calling a “once in a generation” event.

The AMLA Act is built around creating richer and more relevant intelligence by fincrime compliance teams, more ammunition and funding for the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) to analyze and closing the loop with stronger public-private information sharing partnerships.

The initiatives are part and parcel of parallel efforts to finally remove the longstanding stumbling block of impenetrable beneficial ownership structures, a magnet to criminal groups of all stripes, from terror financiers to corrupt oily oligarchs.

The AML upgrades in Congress parallel initiatives at FinCEN.

They are part of a multipronged approach by the U.S. government to strengthen fincrime compliance countermeasures, shift the needle toward “effectiveness” and create richer and more relevant intelligence to law enforcement.

In all, the U.S. Treasury is engaging in a broad overhaul of the country’s financial crime compliance defenses, shifting more toward creating “effective and reasonably designed” programs that produce filings with a “high degree of usefulness” to law enforcement – even though the term has no “consistent definition” in current rules, according to a September notice.

FinCEN is also querying stakeholders to determine if they could better manage risks, resources and threat actors if the bureau created national AML priorities – a similar refrain as in the AMLA – which would be informed by other national illicit finance, proliferation and terror risk assessments published in recent years.

To read the full notice in the Federal Register, click here.

In game of compliance, what is needed? ‘Hustle,’ and a ‘fire in the belly’

While some banks fret on how to fight and file on fraud when it comes to suspicious transaction reports (STRs), the first mistake is not seeing fraud and AML as interlinked, part of the same continuum of illicit.

To be effective professionally and programmatically, compliance teams need to know both to communicate, coordinate and be a true ally of law enforcement.

Banks are breaking down silos between fincrime departments, so a diverse skillset is not only a bonus – it could help futureproof your career.

“You need to be a specialist and a generalist,” said Eric Young, the former CCO at BNP Paribas. “You need to see that big picture.”

Overall, you need to see “how the specialized skills turn into thematic issues and root causes,” he said. “That is one form of leadership. How do you distill all of that data into thematic information that management will understand and have 10-second attention spans to see the bottom line?”  

So what are hiring managers looking for when it comes to the mix of hard and soft skills needed to survive and even thrive in the field of financial crime compliance?

“Compliance is like a basketball team,” he said. “You need to think and act in a very fast-moving game and change roles if necessary. If the ball is going out of bounds, you need to dive for that ball. I look for that fire in the belly, the hustle, to go that extra step.”