• As a partner at one of the world’s largest financial services consulting and audit firms, Dhruv Chawla is part of an elite group of professionals who must knit together, at times, seemingly divergent objectives – follow the letter of rote regulatory processes in a defensive posture to prevent criticism and follow the spirit of the law to fight bad guys.  
• At issue is a constant tension in the space: banks that must comply with anti-money laundering (AML), sanctions, counter-corruption and other laws, regulators scrutinizing for any missteps and law enforcement agencies exhorting financial institutions to “follow the money” and run “effective” programs creating useful intelligence for investigators.
• How to find balance among so many competing priorities is how Chawla cut his teeth in the compliance field over the past more than two decades, with stints at Deloitte and KPMG. He now leads the Financial Crime and Compliance Practice for the Indian operations of PricewaterhouseCoopers (PwC), one of the “Big Four” accounting firms.
• While household name audit firms are known for number crunching, Chawla also knows kindness and emotional intelligence can be just as important for success – as evidenced by the current and historical figures who inspire him – along with a sports superstar known for patience, perseverance, and precision.

By Brian Monroe
bmonroe@acfcs.org
March 26, 2021

Dhruv Chawla didn’t plan to become a financial crime fighter.

But the native of India loved technology and exploring the intersection of litigation, investigations and effectiveness – diverse, complex and nuanced disciplines that ended up being a natural fit for an eventual transition to the field of fincrime compliance.

As a partner at one of the world’s largest financial services consulting and audit firms, Chawla is part of an elite group of professionals who must knit together, at times, seemingly divergent objectives – follow the letter of rote regulatory processes in a defensive posture to prevent criticism and follow the spirit of the law to fight bad guys.  

At issue is a constant tension in the space: banks that must comply with anti-money laundering (AML), sanctions, counter-corruption and other laws, regulators scrutinizing for any missteps and law enforcement agencies exhorting financial institutions to “follow the money” and run “effective” programs creating useful intelligence for investigators.

How to find balance among so many competing priorities is how Chawla cut his teeth in the compliance field over the past more than two decades.

He now leads the Financial Crime and Compliance Practice for the Indian operations of PricewaterhouseCoopers (PwC), one of the “Big Four” accounting firms, along with Deloitte, EY and KPMG.

PwC ranks as the second-largest professional services network in the world, with revenues last year of more than $43 billion.

But Chawla knows nearly every large consulting firm quite well. Not counting EY, he has worked at three of the four over his storied career.

“Quite honestly, I never planned to become a financial crime professional,” he said. “In fact, after graduating from business school, I happened to join PwC in a practice that focused on using technology to help make litigation and investigations more efficient.”

“What has kept me motivated is that in some way we are involved in doing the right thing. I know it sounds like a cliché, but it gives me a sense of satisfaction that I am helping in keeping the society a little safer.”

At PwC, in this role, he guides compliance professionals in many of the most challenging areas in the field, including AML, sanctions, tax infractions, securities, fraud and more, including remediation engagements – a high stress, high pressure environment as enforcement actions in the field have soared into the billions of dollars.

Kindness, patience, perseverance: a winning compliance combination

While household name audit firms are known for topnotch number crunching, Chawla also understands that kindness and emotional intelligence can be just as important for success – as evidenced by the current and historical figures who inspire him – along with a sports superstar known for patience, perseverance, and precision.

“Some of the individuals who I have looked up to are – Mahatma Gandhi for perseverance, Mother Teresa for compassion, Warren Buffet for acumen and Jack Welch for mentoring,” he said. “Another person who over the last 20+ years I have always been inspired by is Tiger Woods for his regimen and determination, and I do wear the ‘Tiger Red’ every Sunday.”

Like Tiger, a true student of the game, Chawla too must take a holistic approach to the full spectrum of financial crime.

To better understand the full panoply of criminal risks, compliance countermeasures and regulatory focal points, Chawla has dedicated himself to understanding both industrywide best practices and regional wrinkles, vital to being able to run reviews for large corporates operating in multiple jurisdictions.

There is also no one-size-fits-all approach to bolstering compliance, it must be tailored for the institution, risks and resources with a focus on results.

“I wish I knew the right combination, but just like cooking, you try to follow a recipe but there are always individual changes that one tends to make,” when reviewing a compliance program before or after an enforcement action and charting a course for improvement.

“I think some of the keys for me are an understanding of issues and ability to simplify them, keeping the desired outcome in sight and working towards it, ability to deal with unexpected outcomes (especially in our field), and most importantly maintaining integrity while being empathetic to both clients and colleagues as we deal with circumstances that can be very stressful.”

At the same time, he is cognizant that to be successful in crafting, operating and remediating a fincrime compliance program – regardless of the region – professionals must expand and broaden investigative skills, experience in uncovering red flags and also harness the power of technology to better analyze and wield data.

To that end, Chawla has worked to strengthen his understanding of the nascent but burgeoning regulatory technology, or regtech, space, which augments the power of human knowledge and decision-making with advanced artificial intelligence, machine learning and automation, key allies in the quest for better efficiency and effectiveness.

He is also passionate in sharing that knowledge.

Chawla is an author, speaker and Chapter advisor the ACFCS India Chapter, offering thought leadership in several recent virtual conferences and events.

Creative criminals, rising regulatory expectations spur evolution in compliance

One of the many reasons it is so important to share insight in the fields of AML, sanctions, fraud and cybersecurity is that they are constantly changing and evolving, based on criminal trends, regulatory expectations or law enforcement priorities.

In recent years, the regulatory environment has become “much more complicated, and the risks are more pervasive as compared to previous years, and that’s a reflection of how the evolution of business, technology and society has happened,” Chawla said.

Even so, the professionals in the compliance space are adapting and adjusting.

“The expectations of the regulators, ability of fraudsters, and skills of the compliance and investigations professionals again reflects that evolution,” he said. “In its truest sense when we talk about compliance, the end goal is still to be compliant and investigations is still to find out the how, who and why?”

But what probably has changed the most is the “means and ways of achieving the desired results,” Chawla said.  

Specifically, for example in case of Cyber-attacks, the need “to synthesize more information in a shorter span of time and respond to the crisis is something which has changed,” he said, with AML, fraud and cybersecurity teams needing to work together more closely than ever, a broad industry trend called convergence.  

What’s more regulators around the globe are more aggressively working together to find chinks in the compliance armor of large banks and corporates – meaning these operations must redouble their efforts to identify and buttress weaknesses before examiners are at the door.

That has given rise to investigations and enforcement actions that are “multi-jurisdictional,” Chawla said. “There is a much better environment of coordination and cooperation between the enforcement agencies and regulators across the world.”

But while regulatory fears and criticism must be addressed, professionals must never forget the reason they do the work: help improve compliance programs, stop money launderers and fraudsters and learn and share with the rest of the community.

So that begs the question: What fuels Chawla and infuses a sense of purpose to his work?

“There are two aspects to it, one is helping a client deal with any type of crisis and making sure that we can guide them through it, and the second is the colleagues I work with and learn from on a daily basis.”

He was kind enough to share some of his knowledge in our latest ACFCS Member Spotlight.

It is difficult to name one person because the answer keeps changing as one matures and grows as an individual.

Some of the individuals who I have looked up to are – Mahatma Gandhi for perseverance, Mother Teresa for compassion, Warren Buffet for acumen and Jack Welch for mentoring.

Another person who over the last 20+ years I have always been inspired by is Tiger Woods for his regimen and determination, and I do wear the “Tiger Red” every Sunday.

I have learned how to ‘quill.’ My daughter loves arts and crafts, and she has pushed me to work with her on her school projects which involve ‘quilling.”

I quite enjoy it as it provides a very good way to learn how to be focused and creative and be prepared to have a client (my daughter in this case) that provides honest and immediate feedback.

I don’t think that there is anything specific that comes to mind as I am open and transparent. I guess one thing would be is that have this aspiration to learn a musical instrument eventually.

I help clients identify, understand, prepare for and respond to the risks and regulations that they must deal with in respect to the ecosystem they operate in.

The way I approach this is one of two ways: either strategic, which means that there is a proactive and preventative approach or tactical, which generally is responding to a crisis.

In the last 20+ years I have been lucky to have had the opportunities to keep myself motivated and excited about this area.

I can honestly say that I can easily spend another 20+ years if the opportunity presents itself.

For me, career trajectory is not the designations/levels, but the relevance one has both to clients and the market. With the ever-changing ecosystem of Financial Crime and Compliance, there is a constant need to learn and adapt as the goal post keeps shifting.

So, I think the trajectory will entail being on my toes and continue to move toward keeping myself relevant.

I have had a lot of advice and it’s difficult to rank them.

But one thing that my maternal grandfather used to say is that whatever you do during the day, make sure when you go to bed you are still not thinking about it.

I guess in a way I have tried to adopt that and basically not overthink my actions and be prepared to deal with outcomes that necessarily might not be what I expected.

I can gladly say that I am still waiting for that….

I wish I knew the right combination, but just like cooking, you try to follow a recipe but there are always individual changes that one tends to make.

I think some of the keys for me are:

• An understanding of issues and ability to simplify them,
• keeping the desired outcome in sight and working towards it,
• ability to deal with unexpected outcomes (especially in our field),
• and most importantly maintaining integrity while being empathetic to both clients and colleagues as we deal with circumstances that can be very stressful.

It is true that the regulatory environment is much more complicated, and the risks are more pervasive as compared to previous years, and that’s a reflection of how the evolution of business, technology and society has happened.

The expectations of the regulators, ability of fraudsters, and skills of the compliance and investigations professionals again reflects that evolution.

In its truest sense when we talk about compliance, the end goal is still to be compliant and investigations is still to find out the how, who and why?

But what probably has changed is the means and ways of achieving the desired results.

Specifically, for example in case of Cyber-attacks, the need to synthesize more information in a shorter span of time and respond to the crisis is something which has changed.

Also, given that the impact of a lot of these incidents are multi-jurisdictional, there is a much better environment of coordination and cooperation between the enforcement agencies and regulators across the world.

I think as mentioned above, the key challenges are still the same.

As the financial services sector continues to innovate and evolve by providing better products and faster services to their clients, how can the regulators keep up to ensure a fair playing field and how can the businesses protect themselves and their customers from the new risks.

One aspect which is sometimes overlooked is the availability of the right talent.

I think that to me is one of the biggest challenges that we currently face and will continue to do so.

Quite honestly, I never planned to become a financial crime professional.

In fact, after graduating from business school, I happened to join PwC in a practice that focused on using technology to help make litigation and investigations more efficient.

What has kept me motivated is that in some way we are involved in doing the right thing. I know it sounds like a cliché, but it gives me a sense of satisfaction that I am helping in keeping the society a little safer.

There are two aspects to it, one is helping a client deal with any type of crisis and making sure that we can guide them through it, and the second is the colleagues I work with and learn from on a daily basis.

I think when people reach out to me for advice and think of me as a role model, I do get surprised.

One of the reasons for that is that I still feel that I have so much to learn and experience myself in this area so how can I be someone who can provide the advice.

As mentioned above, for me it was a sheer coincidence and since I really enjoyed what I was doing I continued to evolve as the area itself evolved in the last 20 years, and I was lucky enough to have the right opportunities and guidance along the way.

The only advice I can give is that you should make sure you have the right skill and an entrepreneurial personality so that after your first break you can make a career out of this.

I think the advice would be similar across any consulting area.

The first is that one must be relevant in the market, which means that you have a good understanding of what the issues and solutions are and have an ability to articulate that well.

The second would be to have a good quotient of empathy. This is important to be able to become a trusted advisor to your clients and be a good mentor to your colleagues.