For some people, paying attention to the many swirling details of life, or a job or a complex puzzle of data points, understanding how they relate to each other, and then clearly and crisply documenting those connections to divine discoveries is simply too much of a challenge.
You get overwhelmed. Frustrated and fatigued with furrowed brows, your mind locked in a fugue state, neurons depleted and defeated. But not PNC Bank Assistant Vice President and Detection and Senior Investigation Associate, Enterprise Compliance, John Waterstram.
He doesn’t just survive in a sea of data points, potentialities and possibilities, he thrives; uncovering critical information for his bank, protecting customers and gleaning vital intelligence to law enforcement as part of a select group in the bank’s anti-money laundering (AML) team that tackles areas of escalated risk.
Waterstram’s passion for learning about financial crime compliance is a natural fit for PNC and ACFCS, he says.
He notes his desire is to not limit himself in only knowing about a small sliver or slice of compliance countermeasures. He is cognizant that criminal groups are equally creative and crafty, already employing physical, virtual and other assets across the spectrum of financial crime to take advantage of any vulnerabilities in a bank’s defenses.
But one of his greatest strengths comes not just from the ability to react to broad-based trends that could intersect his compliance world, but a commitment to recognizing – and just as important, documenting – the details sifted from the various transactional and risk-rated data streams. It is a mantra he learned early on from his grandfather.
“Without a doubt, the best advice I have ever received was from my Grandfather, who liked to say, ‘A short pencil is better than a long memory,’” he told ACFCS. “It is advice that I live by every day, especially when conducting investigations.”
“Documentation is the key to a solid investigation and even a small note can be the difference between a discovery of new fact sets or missing a crucial piece of evidence,” he wrote. “When facing complex networks that employ specific schemes for confusion by design, good documentation is crucial for success.”
But complex investigations require more than the mind of a scientist and heart of an investigator. The person must also be tenacious and have the “spirit of the hunt,” Waterstram told ACFCS, adding that other qualities include patience, the ability to ask for help, and a willingness to step outside your comfort zone to view potentially villainous behavior from new vantage points.
Waterstram, joined PNC Bank in 2009, previously working with Citizens Bank’s Broker-dealer, Citizens Charter One Investment Services Corp. and American Express Financial Advisors.
He holds degrees from The Pennsylvania State University and Pittsburgh Theological Seminary and a certificate in Financial Crime Investigation from Utica College.
Here are some of his thoughts in the latest ACFCS Member Spotlight:
What do you do in your current role?
I am extremely fortunate to be a part of the Special Inquiry team within the larger BSA/AML Compliance department at PNC Bank. The team engages issues of escalated risk facing the bank and helps to resolve them to the best possible outcome for all stakeholders. In my current role, I conduct in-depth investigations and analysis, collaborate with teammates on larger projects and consult, as necessary, with other groups within PNC to provide subject matter expertise.
What does your career trajectory in financial crime look like?
I began my career in the Broker-Dealer compliance segment of the financial services world. Even though I enjoyed helping business partners navigate the regulatory landscape and assisting clients, I wanted to focus on financial crime and anti-money laundering compliance. In 2014, I completed the Financial Crime Investigation certificate program at Utica College (NY) and was given the opportunity to join the Special Inquiry team within PNC’s BSA/AML department. Since then, I have acquired both the Certified Financial Crime Specialist (CFCS) and Certified Anti-Money Laundering Specialist (CAMS) certifications.
My desire is to cultivate my experience and skills to become a subject matter expert in counter-terrorist financing.
What is the best advice you’ve ever received?
Without a doubt, the best advice I have ever received was from my Grandfather, who liked to say, “A short pencil is better than a long memory.” It is advice that I live by every day, especially when conducting investigations. Documentation is the key to a solid investigation and even a small note can be the difference between a discovery of new fact sets or missing a crucial piece of evidence. When facing complex networks that employ specific schemes for confusion by design, good documentation is crucial for success.
What is the worst advice you’ve ever received?
I actually can’t think of any examples, since I try and forget the bad advice.
What would you say are the most important attributes for someone in your role to be able to succeed?
Complex investigations require investigators to be tenacious and have the “spirit of the hunt.” The discovery of complete fact sets can be difficult and frustrating, at times, but the best investigators will patiently attempt to solve problems and find connections hidden in the data. Quality investigations also require the investigator to be flexible and willing to step out of their comfort zone at times, to try new methods and be open to asking for help. The ultimate goal is to learn the facts, manage the risk and, in the case of private enterprise, to get the best actionable information to law enforcement. As investigators, we are all on the same side, working to combat financial crime and the financing of terrorism.
How has (compliance, investigations, etc.) changed and evolved during your career?
I think that the escalating regulatory penalties for compliance failures has prompted many compliance departments to become more proactive in the discovery of issues. There is a necessity for compliance departments to pre-emptively analyze their existing data to try and determine if there are any bad actors/activity within their customer base. Data analysis and machine learning are the arsenal of the future for AML/CFT compliance. These technologies allow teams with limited resources to recognize emerging threats and avoid false positives/negatives.
What do you see as key challenges related to financial crime in your role or in the sector overall?
The speed at which criminal and terrorist networks are applying emerging financial technologies to update traditional methods of financial crime. From crypto-currencies to fintech apps that allow almost anonymous money transfers, there are new ways to transfer value that may not fall within traditional methods of detection. It is key for investigators to be active in their professional development to recognize these new technologies and understand how they can be used for financial crimes.
What motivated you to become a financial crime professional?
I want, in whatever small way that I am able, to help to prevent peoples’ lives from being negatively impacted by financial crime or the effects of terrorism. Financial crime, unfortunately, seems ubiquitous, and its effects are devastating. Whether it is a single family member stealing from a vulnerable individual or a network committing fraud against government welfare programs, there are individuals whose lives will be made more difficult because of the misuse of those resources.
Is there anything that surprised you about your current role?
I would say the resourcefulness of financial criminals to find and employ new methods in their illegal enterprises. I think that it supports the old adage that if these financial criminals would put their energies into legitimate businesses, they would most likely be very successful.
Why did you join ACFCS and/or become CFCS certified?
The decision to join ACFCS and become CFCS certified was easy. I want to be a more complete professional, with demonstrable competencies across the spectrum of financial crime. CFCS allows me to strengthen existing skills and join a community of similarly-minded professionals.
What is the most rewarding part of your job?
I enjoy knowing that, in some way, I am working to help make my community stronger and peoples’ lives better. It is, also, truly rewarding to work with a dynamic team that exemplifies how teamwork and members’ personal commitments to professionalism and excellence can produce results that are far greater than the sum of their parts.