- In this initiative, ACFCS is engaging the fincrime compliance community for wisdom and practical insights on how to enter and rise in a fulfilling but demanding and everchanging field.
- For this tip, we travel to Australia, to see through the eyes of Luke Raven, the Senior AML Compliance Manager at virtual value exchange hub, Cabital. He knows that for longtime fincrime compliance fighters, they will always look back at when they started and wish they knew more.
- Some key overarching guides: to get a foot in the door, let attitude, aptitude and gratitude be your guide as you throw out a wide net of learning, sharing as much as you are capturing as you build a brand as a trusted voice – all the while connecting and collaborating with the most respected thought leaders around.
This Fincrime Career Tips and Tricks is part of the association’s new Community Collaborations series, to share the top tips, tactics and techniques to conquer compliance.
By Brian Monroe
September 6, 2022
For longtime fincrime compliance fighters, they will always look back at when they started and wish they knew what only time, experience and, potentially, very patient mentors and guides have bestowed upon them.
That is also true for Luke Raven, the Senior AML Compliance Manager at virtual value exchange hub, Cabital.
He has been in the anti-money laundering (AML) space for more than 13 years, chiefly in top advisory and analytics roles in banks, crypto and financial services firms in Australia.
In conversations, social posts and interviews, Raven shared some of the best tips and tactics to both break into the field and important lessons – for newcomers and veterans alike – he wished he could impart on his younger self.
For many at the outset of their career, it can be a daunting prospect: learn how all the worst criminal groups in the world – narco cartels, human traffickers, corrupt gatekeepers, terror groups and others – launder their money.
Then learn all the rules around the world to identify and report on what may or may not be these activities.
The general threshold for investigating something further is simply “suspicious,” but that is just a piece of the AML puzzle.
You then must imagine how an experienced investigator would see these same transactional touchpoints crisscrossing across the globe, engage in a thoughtful and defensible investigation in typically tight time constraints and then, finally, convince a nitpicky regulator you made all the right decisions.
While many compliance professionals can do this job, it can take years, decades even, to do it right.
Because at any given institution, professionals must find just the right tension that balances rules, resources and results – with added pressure in recent years that AML, sanctions and fraud investigations must hew more toward “effectiveness” and focusing on higher risks, than simply complying with the technical letters of regulatory duties.
“Achieving the minimum legal compliance standard isn’t the goal, it’s the starting point,” he wrote. “Good compliance isn’t doing ‘just enough’, it’s doing what’s right for the business, the customer, and the community.”
Here are some of his tips for those starting out and perennial lessons applicable to professionals at any stage of their career:
Name: Luke Raven
Title: Senior AML Compliance Manager
Top tips to get your first fincrime job: if you can’t go in the front door for AML, go in the side door – begin by facing crabby customers, then go after crafty criminals
There’s so much interest in #fraud, #risk, #aml and #compliance careers. The question I typically get most though is “OK, but how do I actually GET my first role?”
Not surprisingly, it can be tough, ESPECIALLY when you lack experience! So, though I’m NOT in #recruitment, here’s some tips to help you land the first job!
-Try to link your experience to the role you apply for, but don’t stretch it TOO far.
For example, working in a call center (GOS crew represent!) may not give much #riskmanagement experience, but it gives plenty of other great stuff!
Talk about customer service, difficult stakeholders, high pace / pressure environments, being judged internally and externally by key performance indicators (KPI’s), etc, there are a bevy of parallels with juggling the stress of compliance duties.
-You lack experience, so highlight your ATTITUDE & APTITUDE! Don’t try to pretend you know everything – in fact doing that will trip you up anyway!
More companies than ever are taking a chance on employees who, while lacking technical skills, have high emotional intelligence and a genuine enthusiasm and passion for a role.
-In short, try to always show two things: that you’re KEEN & TRAINABLE!
-Do SOME reading on elements of the role.
If it’s a #KYC or #CDD role, know what that stands for. In that same vein, learn and try to be somewhat well-versed on the classic four pillars of an AML program as this is a bedrock precept that forms the foundational of the modern fincrime compliance citadel.
Read articles that relate to the general discipline.
For example, if you’re applying for a fraud role or anti-scam role, read up on current trends & victims and get comfortable talking about it. This shows you’re interested!
Aim for “comfortable dinner party story” level, not “lecturer giving a speech level.”
When it comes to trying to impress a recruiter or person giving the job interview, think grasping key concepts rather than an orator’s ovation or blustering bloviation on granular details.
Get help: Engage in Link(edIn) analysis to get on radar of recruiters, recruit prolific posters to share secrets of success
– Find recruiters that specialize in this area. Make an introduction – ask for a 10-minute call sometime to set out your passions and interests, and ask them to keep you in mind.
– HELP RECRUITERS HELP YOU! Put in effort! If you don’t put in the effort for them to find you, and fight for yourself, why would they trust you to do so in an interview?
Find thought leaders and follow them here on LinkedIn.
Try to understand, engage and ask questions.
And keep in mind, many of these thought leaders are current or former compliance officers with a deep well of contacts in the public and private sectors.
They could open doors for you or, at the very least, if you gain their trust, they might spend some time coaching you on some of the secrets to their success, potentially even allowing you to use them as a reference for a job interview.
DO engage with job posters / hiring managers. A comment (or to keep it private a message) goes a long way.
Keep it short and simple as these individuals are barraged on a daily basis with requests for time, questions about postings and resumes – even when they didn’t ask for any.
Here is an example of a pithy, positive message that could make a good impression: “Opportunity looks great- I applied! Hope to chat soon!”
And a few dos and don’ts:
- DON’T comment “interested” on job postings – APPLY!
- DO share relevant content (even just the news). Show your interest!
- DON’T harass people you ask for help – they’re busy! Ask once, politely, and follow up a week later.
No reply = move on!
Interview Tips: Talk it out before you walk it out
-Talk out your thought process in a structured way
-Showcase problem solving ability
-Don’t stress about technical competence
-Remember: inexperienced people aren’t hired for what they KNOW, but for what they can be TRAINED to DO!
-Try applying at a resourcing company – they’re good places to learn the ropes!
Here are some potential starting points:
The three-eyed raven: Looking back in time to help you see a brighter future
If I could boil down some of the most important pieces of advice I wish other #financialcrime & #aml professionals would have told me – or that I would tell my younger self – I would say there are five.
There are always more, but I want to focus on the areas of what to learn and how to learn it, connecting with this incredible community and never losing appreciation for the power of ‘why’ and the importance of letting things surprise you.
Those in the know don’t expect this to change any time soon, even with the increasing power and promise of #technology advances, like AI, machine learning and automation.
Five pieces of advice you can start doing today!
1. There’s a LOT to learn, so be selective.
There are thousands of pages of literature out there as my groaning bookshelf attests! You should read/listen/watch in an informed and structured way by prioritizing key pieces and building your knowledge like a puzzle.
If that interesting book doesn’t fill a missing puzzle spot, then put it in the ‘to-read’ pile!
But there are some basics that are universal, so I advise starting with:
- -FATF recommendations
- -regulator & FIU websites
- -AML laws*
And as we mentioned before, even though each jurisdiction will have their own regional wrinkles, many AML programs are built from the same or similar four prongs, with additional guidance to expand and expound proffered by FATF.
- AML policies and procedures.
- An appointed AML officer, with requisite experience for the risk of the institution.
- Fincrime compliance training, for those in and out of the dedicated countercrime function.
- An independent review of the AML program, also sometimes referred to as the AML audit. This can be done internally or externally, but must be insulated from compliance staffers.
In recent years, some AML compliance best practices have been formalized into these classic tines, including customer risk assessments, sanctions screening, transaction monitoring and alert systems and a general shift toward convergence.
In such a structure, for instance, the AML, fraud, corruption, sanctions screening and investigations teams and even cybersecurity teams are interwoven to make better and faster decisions on key exterior threats or bank transactional trends – preventing cases from running in parallel and maximizing spare human and computational resources.
But a word to the wise: this is a lot to chew on – for anyone. Don’t fall down a rabbit hole on one topic.
Fill in that puzzle!
*If law is a chore/bore/leaves you on the floor, the next best thing is someone who talks about it in a digestible way!
2. Always ask yourself “why?”
This is the best piece of advice I can offer anyone! Do it while you (selectively) learn and while you work!
Because regurgitating theory/process gets you nowhere – the ‘why’ is everything. Don’t just DO it, try to UNDERSTAND it.
If you do something ‘just because’ (the law says/you were told/it’s process) you’re GRINDING through it.
Try instead to GROW through it!
As well, try to think of your future self in this scenario.
You are not getting paid to do as many investigations as possible and make as many quick decisions as you can – just to keep the examiners at bay and keep the compliance gravy train moving.
Yes, for some in the trenches, even in the job, dispositioning alerts under the pressure of daily deadlines or numeric goals can be frustrating because you don’t have all the information and oftentimes can’t see the big picture.
But your value, in the future, is that you are paid to think, to make better decisions because you have cut your teeth, sharpened your knowledge and skills and have a deep understanding of the nuanced laundering methods of a broad array of crimes and criminal groups.
3. NETWORK: Working on this net could work for you – big time
I know I have mentioned this in other posts, so you are already thinking: very original, right?
Look, the fact is that many in our profession eschew the basics like #networking – I myself used to call it “notworking.”
Edgy, but wrong!
It is SUPER helpful to follow thought leaders, to have trusted mentors, to speak with industry peers. These folk have – without exception – wisdom, knowledge, or information that you don’t.
- Use LinkedIn
- Ask folks to coffee
- Ask questions and share your views
- Get a mentor
4. Build a broad base: One of the most powerful ideas in fincrime compliance – the bad acts, the bad actors the bad money and the rules to find the funds are all part of one interlinked continuum.
This runs contrary to some advice, but it’s my view: people don’t always become experts by spending YEARS on one thing in one place.
What do I mean by this?
For instance, “10 years in KYC at Bank B” MIGHT make you a #KYC expert, but it’ll more likely make you a somewhat stale “Bank B” expert…
Exceptions abound – and you do you – but I’ve found variety is key.
Even within the same employer, consider other roles!
Don’t throw the earlier advice out either! You still want to be selective AND to ask yourself ‘why’ for each role. If it includes “more money” great, but hopefully you’re learning new things too!
5. Connect with the work: You are a superhero with a story to tell and your work can change and even save lives.
Part of the beauty of moving roles is discovering what you’re more and less passionate about! If you’re lucky, you’ll find things you and that, in turn, might help you excel at it.
Courses, Certificates, Certifications: Not the main course, but they could add some flavor
Industry courses are ‘nice to have’ but NOT ‘essential.’
My advice?️ Don’t do it if it breaks the bank!
Take all of this advice with a pinch of salt and adjust to taste.
You could ask 10 different fincrime compliance officers how they got into the field and they will give you 20 different answers.
Very few people have the same story, hence why breaking into the field can seem so challenging.
Some come from the legal, audit and accounting fields. Others started out fighting fraud and got drafted into compliance because they kept questioning the why and how of these criminals and their rustling red flags.
Still others have come from law enforcement, military or the government, leading the federal investigative agencies that are the tacit customers of the millions upon millions of suspicious reports filed by this community.
As in the hit series, “The Mandalorian,” there is not one set of tips, tactics or experiences that lead to compliance glory, so we can’t just say: “This is the way.”
But there are some key professional, even dare I say, personal, traits that this community of warriors — described by some as the tip of the spear in the fight against financial crime, have in common.
They are creative, curious and courageous.
Compliance to them is more than just rigid rules and riled up regulators. More than the arcane technicalities of backend risk-ranking methodologies and transaction monitoring model validation.
This group is the ultimate underdog, knowing that they face nigh impossible odds against a determined and dastardly adversary, with lives and life savings hanging in the balance.
But in all of this, they keep fighting, sharing and caring, failing and rising each day, revealing a resilience and tenacity that to me is, and always has been, inspiring.
Get involved in sharing your career tips: How It Works
Each quarter, ACFCS is asking its members for advice on various aspects of fincrime careers, from getting your foot in the door to finding a mentor.
This quarter, we’re focused on guidance for launching a career – everything from what motivated you to seek out a role in fincrime prevention, to where you’re seeing hiring opportunities and more.
We’ll gather responses and share them back with our member community. Three participants will receive one year of complimentary ACFCS members (added to your existing membership for current members).
To learn more and submit your tips, click here.