• For Louie Vargas, getting into the field of financial crime and compliance did not just fall into his lap. He fought for it.  
• After several years as an executive administrative assistant, he started to push, bite and scratch into a field that more suited his intuitive, inquisitive and analytical nature: financial crime compliance – eventually landing into the most complex, nuanced regions of the space in the form of global sanctions programs.
• Now, as Principal Compliance Officer on the Sanctions Controls and Technology team at Danske Bank in Copenhagen, Vargas is spearheading several key sanctions-related change program initiatives with a focus on controls and technology-related issues and enhancements.

By Brian Monroe
bmonroe@acfcs.org
June 28, 2021

For Louie Vargas, getting into the field of financial crime and compliance did not just fall into his lap. He fought for it.  

After several years as an executive administrative assistant for a large bank, he started to push, bite and scratch into a field that more suited his intuitive, inquisitive and analytical nature: financial crime compliance – eventually landing in one of the most complex, nuanced regions of the space in the form of global sanctions programs.

Vargas has worked in different types of anti-money laundering (AML), sanctions and investigations units in different stages of maturity over the last decade, leading him to an unassailable conclusion in a sector in constant motion, adapting and reacting to illicit entities of all stripes looking to cleanse ill-gotten gains: complacency is a trap.

“Criminals are always ahead of us,” he said. “IT, data, and continual training are key aspects that all firms need to continue to invest in and be proactive about. Let’s not just figure out solutions for today’s issues but look forward and try to be as forward thinking as possible. If not, we will continue playing catch up.”

These tenets are even more relevant from the perspective of compliance with U.S. and international sanctions regimes, where great agility is required to keep pace with an undulating sea of blacklisted entities, at times expanding, and others constricting, depending on which way the geopolitical winds blow.

Staying nimble has been a hallmark of his career.

In recent years, Vargas has responded to requests for information from the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) and looked for buried, blacklisted entities designated by the Office of Foreign Assets Control (OFAC), groups allegedly linked to organized criminal narco cartels, grand corruption, terror finance and more.  

He began his career at JPMorgan as a Name List Screening (Customer Screening) analyst and was the FinCEN Patriot Act Section 314(a) team lead, a program that broadly queries the whole of the banking sector on certain risky or illicit entities.  

After JPMorgan, Vargas wore many hats at the Agricultural Bank of China, including engaging in OFAC Analyst/Transaction Monitoring/SAR writing/FinCEN314/Trade Finance reviews.

At Deutsche Bank, he conducted Sanctions Quality Assurance reviews and worked on the Sanctions Transaction Review Desk, including filing OFAC regulatory reports.

Now, as Principal Compliance Officer on the Sanctions Controls and Technology team at Danske Bank in Copenhagen, Vargas spearheads several key sanctions-related change program initiatives with a focus on controls and technology-related issues and enhancements.

Central to his success is not just being a powerful ally to law enforcement, but sharing knowledge broadly and liberally to empower the next generation of fincrime compliance fighters – efforts that feed the passion purpose feedback loop.

“I very much enjoy the challenge in helping prevent it, helping others get up to speed in this effort, and feeling like I have a hand in protecting our financial institution and society,” Vargas said.

“I have worked in different industries in the past and have worn many different hats but cultivating a career in the compliance/financial crime field was an unexpected blessing. It has given me a sense of purpose/satisfaction I have not felt in other roles. I truly feel this is a career, not just a job.”

Vargas was kind enough to share some of his insight in our latest ACFCS Member Spotlight:  

My family inspires me the most to always do my best and uphold and display integrity.

I am also inspired by some former and present coworkers, managers and my current mentor. I won’t mention any names to avoid putting anyone on the spot.

I had fun learning and testing out two new investigation tools that allow us to search more than one search engine at a time and review search results against current customer and transaction data.

I suffer from general anxiety, so sometimes all this fun can be overwhelming. But I have been taking steps to learn how to address this in hopes to reduce and address negative effects.

I am Principal Compliance Officer on the Sanctions Controls and Technology team at Danske Bank in Copenhagen.

I have also provided guidance on control and technology related topics and issues.

Dealing with different stakeholders around the bank can be tricky, but it’s our remit to address foreseeable risk and help educate to enhance processes and technology behavior to ensure our tools and analysts are properly prepared to mitigate those risks.

I very much enjoy the challenge in helping prevent it, helping others get up to speed in this effort, and feeling like I have a hand in protecting our financial institution and society.

I have worked in different industries in the past and have worn many different hats but cultivating a career in the compliance/financial crime field was an unexpected blessing.

I have been able to see different types of programs in different stages of maturity having begun my career at JP Morgan as a Name List Screening (Customer Screening) analyst and was the FinCEN (314a) team lead, at the Agricultural Bank of China where I wore many hats that included OFAC Analyst/Transaction Monitoring/SAR writing/FinCEN314/Trade Finance reviews.

At Deutsche Bank, I conducted Sanctions Quality Assurance/worked in the Sanctions Transaction Review Desk/filed OFAC regulatory reporting.

Today, I am currently driving a few Sanctions-related change program initiatives and focus on controls and technology related issues and enhancements.

I hope to continue learning and growing with the hope to one day take on a supervisory role within Sanctions or other Financial Crime units. Here we are also now living abroad. I did not think that would ever happen.

Do not stretch yourself too thin.

Slow down, you don’t have to work that hard or “that is not suspicious activity, it is normal course of business.”

Humble, willingness to learn, learning how to deal with and work in the ‘gray’ area, and teamwork/collaboration is important.

It has given me a sense of purpose/satisfaction I have not felt in other roles. I truly feel this is a career, not just a job.

In addition, this line of work permits me to conduct research which as a history major and being very inquisitive by nature, is something that I look forward to everyday.

During my time in this area, risks, red flags, and typologies have changed and will continue to do so as the criminals look to stay ahead of the good guys. Investigations have so far remained largely the same, but we are now seeing more technology being used to help reduce human effort but also provide more information quicker than before.

Like everything else, these tools cost money so different financial institutions have different tools.

In addition, financial institutions have some more and some less tools available to investigators.

But with more companies looking to help and offer solutions and the implementation of AI to cut down on repetitive tasks, this will only continue to evolve, [particularly with a stronger focus globally on effectiveness and results, at the country and institution level].

Criminals are always ahead of us. IT, data, and continual training are key aspects that all firms need to continue to invest in and be proactive about.

Complacency is a trap.

Let’s not just figure out solutions for today’s issues but look forward and try to be as forward thinking as possible. If not, we will continue playing catch up.

I remember living through 9/11 in NYC and feeling helpless.  

In 2017, my family and I were a couple of blocks away from the attacks taking place in Barcelona. Being a financial crime professional has helped me feel like I am able to do my small part to hopefully stop future incidents.

As well, getting a chance in the field and buying into the fact that we can make a difference despite not getting much recognition. We are not revenue generating, but we are revenue saving.

As I mentioned earlier, it feels good to know you have an impact on creating a better compliance culture around the bank and helping protect the financial institution and society.

The sanctions world has become increasingly volatile and its importance or effectiveness has come into question.

The Nordics are new to a lot of the issues US banks have already begun to remediate, so it was a bit of a culture shock that they have not done more in certain areas. Never a dull moment to say the least.

I have been following ACFCS since it was created and what convinced me then remains true today: it is more well-rounded than other Compliance/Financial Crime certification programs.

I want to maximize my learning potential, not just focus on one portion of our compliance landscape. In addition, the questions are practical in nature and not intended for memorization.

As mentioned before, I worked many different jobs prior to arriving in Financial Crime. It was luck, to be honest.

I had reluctantly been an Executive Assistant for four years at JPMorgan. I finally worked up the courage to let my manager know that I will look for internal mobility for a new role where I could learn and hopefully do more but had no specific idea of what I wanted to do.

I started applying for different roles around the bank with no success. I asked a few of my fellow EA friends to let me know if they hear of any opportunities.

One such EA heard from a former manager in her group that left to head a newly formed Client List Screening team and they were looking for a hybrid assistant and analyst.

I interviewed, expressing my interest and how I felt I could fit in and if there was a possibility of becoming a fulltime analyst after some time. I guess the interview went well because they decided to offer me an analyst position.

The rest is history. My advice would be to not give up if you want to try something new, it takes persistence. Do your research, try to obtain a certification), and try networking with those who are doing the role you would like to get into on LinkedIn.

If you have no risk or compliance experience, you might have to start from the beginning as an analyst, but if you have done other things that are relatable or have a JD, you might have a chance to come in at a different level.

Networking at industry events and LinkedIn, reading FC related articles, always trying your best and sharing ideas on gap or issue remediation, try and get a mentor (especially in FC), and open conversations with your manager so they can assist in your development and look out for opportunities for you to grow and advance.

It’s always good to be a good teammate by offering guidance and assistance to newbies along with vets. A lot of grey area to deal with so collaboration is important.