Garry W.G. Clement, CFCS, CFE, CAMS
President & CEO Clement Advisory Group
Garry Clement started White-Collar Investigations and Consultant’s Group operating as the Clement Advisory Group (CAG) in April 2009 following a period with an international consulting firm as a Managing Director commencing in 2007. He established thirty-four years of policing experience; thirty with the Royal Canadian Mounted Police (RCMP) in a range of investigative portfolios, undercover assignments and management roles, and four years as the Chief of Police for Cobourg. He retired from the RCMP holding the national position of Director, Proceeds of Crime (Superintendent).
Garry is an internationally recognized expert in the areas of money laundering, interviewing, white-collar crime, organized crime and detection of suspicious activity having been one of the pioneers of the RCMP’s proceeds of crime program. During his tenure in the RCMP, he worked in the areas of proceeds of crime and money laundering as an investigator, undercover operator and manager. Additionally, he served as a Liaison Officer in Hong Kong, where he worked with law enforcement in the Asia- Pacific area dealing with counterfeiting, fraud and money laundering.
What do you do in your current role?
CAG is a boutique anti-money laundering consulting firm and a licensed private investigative agency specializing in the entire range of financial crime. CAG relies on AML consultants and investigators who have extensive experience in anti-money laundering, financial crime investigations, and training. Each expert has at least 30 years of practical experience as regulators, auditors, examiners, analysts, attorneys or special agents in anti-money laundering or related fields. All consultants have extensive training experience and have been recognized for their excellent communication skills. Many are certified fraud examiners, forensic experts and anti-money laundering specialists.
What does your career trajectory in financial crime look like?
In 1983 I was tasked in overseeing the implementation of a proceeds of crime and money laundering investigative program within the RCMP. Having just completed a Certificate in Business Administration from Ottawa University I continued my studies over a 10 year period working towards and Honours Bachelor of Commerce. During this same period I completed Certificates in General and Advanced Police Studies from the Canadian Police College and a Teacher of Adults from Algonquin College along with numerous police courses including computer crime, terrorist negotiation, and fraud investigations and advanced interviewing.
Recognizing the value of acquiring certifications for specializations I worked with and received certifications from:
Association of Certified Fraud Examiners – 1991 and became a Life Member
Association of Certified Money Laundering Experts – 2003 and was a former Board of Advisor Member and founder of the Toronto, Montreal and Vancouver Chapters
Association of Certified Financial Crime Specialists – 2015 recognizing the inherent value in focusing on the totality of financial crime which conforms to the CAG model of helping organizations implement financial crime controls.
I have been widely quoted by many published authors in such books as: The Road to Hell, (Julian Sher) an overview of the Hells Angels, Dispersing the Fog, (Paul Polango) an overview of RCMP, Smokescreen, a book focusing on my 1996 undercover operation into tobacco smuggling from the US into Canada which resulted in the highest civil penalty against the cigarette companies in Canadian History, Paper Fan (Terry Gould) flowing from my tour in Hong Kong , the book describes the international search for Wong, Lik Man a notorious “triad” member and other magazines and news print, as well as having been featured in the national news program W-5, and an NRA documentary on border security. I am a frequent guest of CTV, Global and CBC National News.
What is the best advice you have ever gotten?
I was fortunate to have worked with a number of individuals who were my mentors throughout my career. The two pieces of best advice were:
Put your head down and work hard and never wait for things to happen, make them happen for yourself and do not stay in an organization and become disillusioned, you will know when it is time to leave and therefore leave on a high.
What is the worst advice you have ever gotten?
I would have to say that early in my career after embarking in the field of financial crime controls, being told that our efforts would result in less crime. As we know financial crime has changed over time but continues to grow and sadly has demonstrated the inability of the collective law enforcement arena to make a substantial impact.
What would you say are the most important attributes for someone in your role to be able to succeed?
I think for someone to succeed in this field it is important to accept that no one is an expert or can hope to be in all areas. Notwithstanding this, it is up to each and every person to put in the time and energy to become the best that they can in the particular area they are working. This includes continuous reading and research, joining and participating in organizations such as the ACFCS, offering to write papers on financial crime topics, and accepting continuous learning.
Lastly I would suggest finding a mentor, there are many of us out there who are nearing the end of their careers and want to ensure the “good guys” maintain an equal capability to organized crime in the years ahead.
How has (compliance, investigations, etc.) changed and evolved during your career?
When I first started in this industry it was common to witness duffle bags of cash being delivered to financial organizations without any questions being asked. For the most part because of the lack of any will to prevent the laundering of criminal proceeds criminal organizations were disorganized and for the most part were unsophisticated relative to the business environment.
Today criminal organizations are as equally sophisticated as law enforcement and compliance officers. They are able to adjust to whatever controls are implemented and rely more frequently on cybercrime techniques. Unfortunately too many still put greed above ethics which plays into the hands of organized crime.
What do you see as key challenges related to financial crime in your role or in the sector overall?
As a world we have become totally reliant on the internet and all the devices which make us more connected 24/7. Many fail to realize that the internet was never designed for what it has become and due to the pace of change with programs few of us are able to stay on top of all the challenges. Furthermore many organizations are failing to understand that with over 1 million new viruses developed every year, it is only a matter of time before an attack is successful.
On top of this expertise is not static and sadly there has been an erosion of individuals who are willing to accept that to stay current it takes a full commitment with many sacrifices. This also includes law enforcement which sadly in my view is falling farther behind thereby providing the upper hand to criminal organizations.
In North America the legal community continues to argue that forcing them through legislation to comply with our money laundering laws would violate solicitor-client privilege, when in fact all arguments for legislation focused on the roles they play in real estate transactions, acting as financial advisors, etc. Sadly the legal community’s unwillingness to work toward thwarting financial crime has made them a target of criminal organizations and just as in any other profession there is always someone willing to assist.
What motivated you to become a financial crime professional?
Commencing in the mid-70s and for a period of 11 years I worked in the field of drug enforcement, much of which was focused on undercover operations. Following my 1981 undercover operation which resulted in very notable organized crime figures being arrested and flowing from the criminal trials that followed I came to the realization that arresting individuals, seizing their drugs and putting them in jail was only a half-finished investigation since they were keeping their illicit proceeds and having them available after serving their sentences.
My boss of the day, who is very notable in his own right, Rod Stamler was one of the most progressive bosses I had the pleasure of working with and through discussions he also recognized the need to go after criminal proceeds in order to hurt criminal organizations.
Is there anything that surprised you about your current role?
I would have to say that it is somewhat frustrating to realize many organizations have failed to grasp basic concepts and have been closed relative to maintaining an internal focus. By this I mean I fully believe that organizations would improve if they were to recognize the value of having someone with financial control compliance expertise on their Board of Directors so that appropriate oversight is being exercised and understood by someone with the requisite skills.
Secondly I find that the fact many large organizations fail to go outside for their compliance specialists has resulted in what can only be described as the same old, same old approach. Just like turning over Chiefs of Police engaged outside the organization, so too must compliance officers in order to have fresh set of eyes and a fresh perspective. Lastly internal audits need to also include an outside professional thereby ensuring the approach and focus stays current and robust.
Why did you join ACFCS and/or become CFCS certified?
I believe that to maintain expertise it is essential to capitalize on what organizations can offer. For me the ACFCS dove-tailed into what CAG was espousing to clients; a need for financial crime control strategies, not just siloed AML, Fraud, Cybercrime programs. Additionally as I had been on the Board of Advisors at ACAMS with many of the same professionals that currently serve on the Board of Advisors for ACFCS this immediately demonstrated that the ACFCS was headed in the right direction and would provide a value-added perspective for organizations.
I chose to become certified as I believe if one is to be part of an organization and show a commitment, it is essential to capitalize on what is being offered. Additionally as someone who provides training and presentations I believe it is imperative to lead by example.
What is the most rewarding part of your job?
I am blessed with being able to present to organizations at all levels and in many geographic regions of the world. I continue to meet phenomenal and brilliant people with a strong desire to make a difference. Lastly the ability to be able to impact legislation through appearances before House of Commons and the Senate and through ongoing media interviews is extremely satisfying.