- In this new initiative, ACFCS engages the fincrime compliance community for wisdom and practical insights on how to enter and rise in a fulfilling, but demanding and ever changing, field.
- We are asking minds across the spectrum and around the world of compliance officers, regulators and investigators to share some of their secrets to success.
- Some of the questions: How can you take the first steps launching a career in the midst of a pandemic? And for those already working, how can you continue to develop professionally and take it to the next level?
- For this tip, we get advice from a federal investigator with nearly 30 years of law enforcement experience.
- His early love for Sherlock Holmes movies sparked an interest in solving criminal cases, but what ignited a lifelong journey of learning was better understanding of financial crimes – both how fellow agents followed the money, but also how scammers, fraudsters and cyber hackers crafted their schemes and worked to evade detection and legitimize sullied funds.
By Brian Monroe
March 30, 2021
With minor edits by ACFCS VP of Content, Brian Monroe
In this new initiative, ACFCS engages the fincrime compliance community for wisdom and practical insights on how to enter and rise in a fulfilling but demanding and everchanging field.
We are asking minds across the spectrum and around the world of compliance officers, regulators and investigators to share some of their secrets to success.
Some of the questions: How can you take the first steps launching a career in the midst of a pandemic? And for those already working, how can you continue to develop professionally and take it to the next level?
For this tip, we get advice from a federal investigator with nearly 30 years of law enforcement experience.
His early love for Sherlock Holmes movies sparked an interest in solving criminal cases.
But what ignited a lifelong journey of learning was a quest to better understand financial crimes – both how fellow agents followed the money, but also how scammers, fraudsters and cyber hackers crafted their schemes and worked to evade detection and legitimize sullied funds.
One critical piece of advice: “Don’t get stuck in the mud,” he said, noting that this field is an ever evolving cat-and-mouse game with organized criminal groups the world over employing endless creativity to find compliance and counter-crime vulnerabilities in jurisdictions, regulatory oversite gaps and exotic payment types with weak controls.
As a result, investigators – whether in the framework of AML, fraud and cyber or government agents at the local, state and federal levels – must be courageous, fearless and willing to shine a light in the dark corners of finance they themselves still don’t fully understand, a powerful catalyst to personal and professional growth.
“Always look, always ask why,” he said. “Look for and don’t be afraid to find and prosecute fraud in areas people have not done before.”
Name: Michael Loughnane
Company: Loughnane Associates. LLC
Country: United States
What initially attracted you to the world of financial crime prevention? What keeps you here now?
I grew up a fan of Basil Rathbone Sherlock Holmes movies and, of course, Colombo (I have a signed Peter Falk photo on my wall). So my interest started very young.
I attended Northeastern University for Criminal Justice and NU had a fantastic internship program. That is how I got started.
My first internship was six months as a radio operator for the DEA in NYC in 1978. It was exciting to be a part of the action on one end of the radio, closely supervised by professionals, of course.
But on the last day, an agent who was running the desk walked me out. We did not get along well so I was surprised when he turned to me and asked if I was planning to come back in another six months.
When I said yes, he said great, I would make a good agent someday, but I really needed to ask myself if this kind of work was what I wanted. It really made me think.
Great work, great mission, but that also made me realize it was not what I wanted my life to be for 30 years.
Six months later, during internship interviews, I was interviewed by the Assistant Inspector General for Investigations (AIGI) for the Department of Transportation (DOT) Office of Inspector General (OIG).
We talked about fraud cases and the work they were just starting to do (the IG Act was just enacted).
The challenge of financial crime cases hooked me. I became an intern and after two internships was able to become an agent. In fact, instead of going to my graduation I was down at a Federal Law Enforcement Training Center (FLETC).
How did you overcome the experience gap for those new to their industry, field or country?
I don’t know if you can ever say you have overcome the experience gap.
If you are not learning something new, something is wrong. In my 27 years of law enforcement, I am not sure I have ever experienced two identical cases. There were always new approaches, new sources, new opportunities.
I used my internships to understand the system and organization expectations. When I became an agent, I was started with small, low priority cases, to get me out on the street and working cases, learning to deal with information sources, government sources and other law enforcement organizations (LEOs).
I think I got every case wrong, but I had a great special agent in charge (SAIC) and senior partners who helped me understand my mistakes and learn from them.
This was important (and why I loved the IG environment) because we did not have a lot of agents and two agent investigations were a luxury. Pretty much it was getting on a plane every other week and working cases around the country on my own.
Everything from predicating a case to referral was on me. It took a few years before I really felt I was able to work on my own.
Long story short, after six years I was assigned to open a one agent office in Boston (my home town) and I had the perfect life: an agent on the road with a pager. And, all of sudden, it was twenty years later and I was in DC being the guy to mentor others.
It went by so fast.
What’s your advice to someone just starting out in the industry and wondering how to chart their career path?
Best advice is to recognize there are people smarter than you, good guys and bad.
You can actually learn from both, from investigation to understanding how the bad guys think. Especially in financial crime cases, to see the system the way they do is a big advantage.
Next, don’t get caught in the mud. Things are always evolving and changing. Cash to crypto, paper to hard drives. Financial crimes change as well.
One of the things I was good at was to find fraud in areas not previously looked at.
For example, I had the first successful prosecutions in disadvantaged business enterprise fraud, worked some of the first identity theft cases, one of the first software piracy, suspected unauthorized aircraft part cases, and more.
Always look, always ask why.
Finally, obtain the credentials that go with your work. Demonstrate you have the knowledge and that you are willing to apply it as you learn the job.
Early in the era of cybercrime, I built the computer forensic and investigation program at the Environment Protection Agency (EPA) OIG. Part of that was to work with information technology (IT) security to trust us and alert us when an incident occurred.
In doing that, I obtained a Certified Information Systems Security Professional (CISSP) credential to demonstrate to them I understood their issues so they would listen to my investigative concerns.
I was able to build a penetration testing lab for their use where I would sit with them, learn what they were dealing with and help them to work with me on incident response.
Any advice or suggestions for job-seeking during the pandemic?
The market for financial crime investigation experience is booming.
The requirements for the regulated community are becoming more strict. As I say in the training I do today, financial crime is all about money and the processes not only to generate revenue but to control it. This means a financial crime investigation skill set can fit in anywhere.
So, be patient and find the place where you are happy and challenged.
And, get into the professional networks and threads. The advice is invaluable, and there is always an announcement for positions or projects.
Any other thoughts or guidance on getting started in fincrime careers to share?
You need to be the right person for this type of work. It is not often a “door-kicking” type of work (it does happen, but not in the frequency of other types of LE).
The challenge is cerebral, and when you are engaged, you often become the expert in the room, including the prosecutors.
I had a hacking case, for example, working jointly with one of the big agencies. We actually ended up going to trial. I was the agent who presented the case to the grand jury, and the agent who sat at table.
You will grow up fast in this work and you may feel like you are prepping for an exam every day.
But, as in my career, when you are sitting in the US attorney’s office, across the table from a former Attorney General who is representing the defendant that you arrested, and there is no challenge to the way you did your investigation, nothing tops that.
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.