By Brian Monroe
bmonroe@acfcs.org
June 9, 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 travel to New York and enter the ever-undulating world of securities trading, where one person believes the key to countering financial crime in all its forms is seeing that the requirements to fight fraud, craft anti-money laundering programs and crimp corruption are all part of one interlinked continuum – a living, breathing interwoven governance framework.

“The most common triggers of fraud are greed and lifestyle,” she said. “Fraud and corruption are interrelated.”

And to fight back, you need an integrated approach, a strategy of particular import for a company with decades of experience and reputation on the line juggling some $17 billion in assets.  

In essence, the various players – in and out of a company – whether they are dedicated compliance champions, internal or external auditors, whistleblowers, business leaders and trading superstars, even human resources, must communicate, coordinate and collaborate to prevent pockets of illicit activity from cropping up and festering.

“I strongly believe that internal communication should start at the top and communicate at all levels,” what regulators in recent years have called in enforcement actions, a “tone at the top.”

“Whether external or internal communication, the ethical and integrity message must be visible, and hotlines and whistleblowers communication must set up and retaliation cannot be allowed.”

Critical also to success: being cognizant that mistakes will happen, but also a deeper realization that occasional missteps are the path to ultimate growth – and not hiding those can lead to uncovering an Enron-scale fraud at the beginning of its terrible cycle, rather than at the end.

“Eliminate the fear factor: Encourage yourself and others to explore different paths and to make mistakes that can build your confidence to take risks in real life.”

Name: Winnie Sokoloff

Organization: Brookfield Public Securities Group      

Title: Administrative assistant, legal and regulatory

Country: United States

What’s your advice to someone just starting out in the industry and wondering how to chart their career path?

I would recommend:

1.       Speak/Consult with experts, friends, or family to help in creating your own career development plan. That will ensure you are taking the right steps in order to avoid the spending and wasting of time on unnecessary education.

2.       As I mentioned above, certification programs, including ACAMS, ACFCS, or any other compliance certification and training programs.

3.       Update your resume to reflect your most current job descriptions, latest certification and industry collaborations, blogs, whitepapers and the like.

4.       Create a LinkedIn account or update your profile. Find and connect with the biggest names, most respected leaders and with thought leaders in areas you would like to learn about and grow in understanding.

5.       Eliminate the fear factor: Encourage yourself and others to explore different paths and to make mistakes that can build their confidence to take risks in real life.

Any advice or suggestions for job-seeking during the pandemic?

1.       Network and connect: Job seekers can connect with people at a company you want to work for and learn more about the company and the jobs they posted.

2.       Social media – human connections: Start with LinkedIn. Join groups and connect with people by being active. Just in a few fields of expertise in the compliance field, whether anti-money laundering, fraud, corruption and others, there are tens of thousands of professionals working together to analyze and share insight on laws, guidance, trends, gaps, criminal vulnerabilities and regulatory focal points.

3.       Social media – company connections: Facebook and Instagram to connect with brands.

4.       Resume refresh: Make sure to update your resume and cover letter.

5.       Interview review: Take some time to touch up on your virtual interviewing skills.

6.       Always prepare yourself: Spend some time to reskill and upskill yourself.

7.       Adaptability, positivity, marketability: Be adaptable, flexible, and have a positive attitude.

8.       Play the field in your field: Job searching and a need to be patient and understanding.

9.       Self-evaluate: Take a few classes, training sessions of certifications in areas you are weak, want to grow or eventually get hired.

10.      Charity to prosperity: Consider volunteering with an organization you really care about.

Any other thoughts or guidance on getting started in fincrime careers to share?

The most common triggers of fraud are greed and lifestyle. Fraud and corruption are interrelated.

Some of the major types of fraud include asset misappropriation such as cash, non-cash, fraudulent disbursement, false insurance claims, credit card fraud, false government benefit claims and others.

Asset and revenue overstatement or understatement, bribery and fraudulent expense claims are also considered to be fraud. Fraud can happen anywhere, whether at home or abroad.

Fraud is equal to dishonesty and it’s difficult to identify.

Consequently, fraud policy should be in place as a key component of any existing compliance program.

But, surprisingly, what can be a fraud’s greatest ally? The company itself.

For instance, when management chooses not to believe or wants to know, or even investigates any further a potential instance of impropriety, but rather keep the details from emerging for fear of financial or reputational harm.

It’s just because they didn’t want to get blamed or be targeted in any lawsuit.

For example, one of the instances this occurred is the Enron case. I think that management should have engaged in more robust risk management practices to detect the root cause and the next potential risk.

One can be involved in fraud unknowingly just due to lack of understanding or knowledge.

Organizations are encouraging the use of whistleblower programs related to the reporting and detection of unethical behaviors or any conduct that’s considered inappropriate in the workplace.

Humans make mistakes, whether intentional or unintentional, but the reality is their behavior of misconduct will harm others.

Why do people act unethically? Perhaps too much pressure, an “everyone is doing it” mentality? Pressure from the management or the internal cultural norm diverges from industry best practices?

There are many reasons, both internal and external, personal and professional.  

Internal Controls should be the foundation of a firm’s governance structures and will amplify the operation’s ability to manage and monitor risk effectively, and also be in compliance with applicable laws and regulations, including those that fight fraud, money laundering and corruption.  

Policies and procedures should be in place to safeguard a firm’s assets, to provide accurate financial reporting, security and Integrity in order to achieve the organization’s objectives and goals.

The importance and benefits of audits are manifold: monitoring, auditing, testing, and periodic evaluations of anti-corruption compliance programs in order to detect criminal conduct.

In addition, its ability to frequently evaluate the effectiveness of a compliance program in an organization. Internal auditors are the eyes and ears of the audit committee – a powerful ally to find compliance gaps before regulators are at the door.

These groups should work in concert with external audit teams, which typically focus on how organizations identify risks relevant to any fraudulent financial reporting and to ensure that capital markets information is delivered to investors, clients, shareholders and partners in an accurate way.

In sum, I believe that the compliance policies and procedures cannot be excluded from the firm’s governance framework and cannot act in a silo.

The purpose of compliance is not just to focus on individual areas and program elements, but to act in coordination and engage in information sharing across finance, IT, operations, legal, internal audit and human resources.

Therefore, firms must engage in effective internal controls.

If an organization fails to prevent fraud and corruption, as a result, it can have significant legal, financial and reputational consequences.

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.