When it comes to financial crime compliance, a lot can change in 20 years. Just ask Jorge Guerrero, the chief executive of Optima Compass Group, a consultancy that, like the man himself, is pushing the boundaries of convergence and technology to better counter criminals.
The Texas resident and former Manhattanite has seen the field of anti-money laundering (AML) go from an afterthought – at times given to the bank worker with too much time on their hands and just enough smarts to know not ask too many questions – to a front-burner issue commanding the attention of top executives, boards and government agencies.
But in a field buzzing with the electric hum of new technologies, one piece of advice from an unlikely source guides Guerrero – a simple phrase from a New York doorman before he went to law school that was “prophetic” in its prescience: follow the money.
The axiom has guided Guerrero, who was born in the Dominican Republic, even as the tools available to compliance professionals have gone from “sigh” to sci-fi.
Currently global banks, regulators and fintech firms are tinkering with the intersection of AML and artificial intelligence, machine learning, blockchain, and swimming social media with classic customer details to better gauge risk, a global initiative to give richer and more valuable intelligence to law enforcement, satisfy ever more nitpicky regulators and counter increasingly creative criminals.
Here are some of his thoughts in the latest ACFCS Member Spotlight.
What do you do in your current role?
I am the Chief Executive Officer of Optima Compass Group, where I have worked for 12 years. I am also a lawyer. In my job, I work with banks, money services businesses and other financial institutions to improve in a broad array of compliance areas, including AML, identifying and countering fraud and also crafting stronger cybersecurity defenses, responding to attacks and recovering systems and data to restore normal business operations.
What does your career trajectory in financial crime look like?
I worked in big Washington, D.C. firms when I first graduated from law school. As well, I had a law firm in New York. I was also the first president and cofounder of the National Money Transmitters Association. I was also a financial crime compliance officer at Vigo remittance for three years. Then I jumped into AML consulting.
What is the best advice you have ever gotten?
Follow the money. Literally. That was from a doorman at a building in New York where I was working during the summer as a part time job before I went to law school. I told him about my plans, and he said, “I have one piece of advice for you. Follow the money.” As it turns out he was prophetically right.
What is the worst advice you have ever gotten?
Don’t sweat the little stuff. In AML, you have to sweat everything. Because little details can end up being pretty important in compliance and in law. Both of them. One example of that is some banks may not realize the compliance obligations that apply to financial institutions don’t just come from regulations. They may come from opinions issued by the regulators but also legal opinions by the courts. It’s important for compliance professionals to take a more holistic approach to considering other sources of obligations.
What would you say are the most important attributes for someone in your role to be able to succeed?
In the compliance field, I would say being able to see the big picture. Being able to connect what you do to the greater consequences of what you are doing. We are all doing our little parts but it’s for a greater good. That places greater importance on doing it well.
On that note, what do you think of U.S. regulators’ calls for convergence?
It’s critical to be converged and know compliance requirements, best practices and guidance beyond AML, including fraud and cyber. Not doing that is like going into a fight with one hand tied behind your back. You won’t get much for your effort. Limiting the information you have at your disposal to process is generally not a good idea, particularly when we deal with the complex issues that we see in the compliance world.
That’s because when it comes to AML, it really cut across multiple subject matter areas. For instance, something that starts out as a money laundering attempt will get you into the underlying crime. And the underlying crime may be a cybersecurity event. That affects the institution but also affects the client. That one investigation may evidence deficiencies in information technology or processing, not necessarily in compliance. You truly have to have a comprehensive view of the risks in order to apply effective controls.
How has (compliance, investigations, etc.) changed and evolved during your career?
When I first started out, the role of the compliance officer was greatly diminished. The person that would be appointed as a compliance officer was the one the owner finds reading the newspaper all the time and not doing a lot of work. That person was eminently qualified to be the compliance officer. (Guerrero laughing.) But the position has evolved to requiring a more technical and scientific approach. Now, compliance teams use big data, analytics, predictive logic and algorithms in developing tools to better help us do our job today.
As for my company, that is what we do. Our AML Compass program uses artificial Intelligence to connect our system to social media, and gets a better picture of the customer that we have to know. Before, we had to know customer transactions to know them and see if they have the financial wherewithal to do the transaction, looking for things that don’t make sense, such as a person with an average salary depositing or wiring that in a month.
But now we have the ability to know who the customer truly is to better understand if, in a particular transaction, it is being done by the actual customer or a fraudster. For instance, it can be very advantageous to know if a person is trying to do a transaction in New York, but their social media profile says they are in Los Angeles. That begs many questions. Is that just a flaw in a computer system? Or is it maybe the transaction is not done by you. AML compliance is becoming a very technically demanding position, whereas before you pretty much just needed to have a pulse and show up.
What do you see as key challenges related to financial crime in your role or in the sector overall?
Technology. And the ability to mask identities, mask transactions, and transcend geographic boundaries. But also technology is the antidote. It’s one of the antidotes but you also need a clear thinking and intelligent person applying those controls and driving the technology. It’s critical. The tech helps with the heavy lifting by reducing the universe of transactions to only those that need to be looked at. The bottom line is even the reduced number of transactions need to be looked at. But looking at them requires evaluation, analysis and conclusions. You have to use all of your senses and knowledge to both protect the institution and also apply surgical controls to maximize resources.
What motivated you to become a financial crime professional?
It’s intellectually challenging. But also, I have seen a lot of movies. Being in compliance kind of feels like being an old-time private investigator.
Is there anything that surprised you about your current role?
That it exists. When I went to law school this was not a possibility. The role of AML or financial crime compliance officer was not discussed at all.
Why did you join ACFCS and/or become CFCS certified?
To enhance my skill set and stay up to date on the issues in this ever-changing landscape.
What is the most rewarding part of your job?
That we are on the right side of issues. This job is not only professionally rewarding, but you feel like you are making a solid contribution to society. It’s rewarding financially, intellectually and rewarding morally.
Jorge Guerrero bio:
Jorge Guerrero, a lawyer licensed in New York, concentrates in the areas of money laundering and fraud prevention and controls at financial institutions. He holds a Master of Science Degree and has worked with banks, non-banks, regulators and law enforcement agencies in the area of anti-money laundering compliance since 1996.