‘Innovate or vegetate,’ to survive, thrive in rapidly evolving world of financial crime compliance
Sunday, February 14, 2016
Posted by: ACFCS
Ravon Taylor III co-founded Taylor Griffin & Associates AML Solutions in September 2015 and serves at the capacity of managing partner.
He is a Subject Matter Expert (SME) that has had a hand in nearly every aspect of Anti-Money Laundering from Enhanced Due Diligence (EDD) to 314(b) and has spent over eight years spanning the country working with banks of all sizes from Community Banks to Multinational Financial Institutions.
Ravon was a part of a specialized team recruited to Baltimore in order to assist M&T Bank in completing a project that was instrumental in addressing key discrepancies found in the institution’s risk management agenda, which was found to violate federal anti-money laundering regulations. These key changes helped M&T Bank complete the acquisition of Hudson City Savings Bank.
What do you do in your current role?
I am a managing partner at Taylor Griffin & Associates AML Solutions which is a full-service boutique consulting firm dedicated to serving the Anti-Money Laundering needs of both bank and non-bank financial institutions. My current role also includes client on-boarding of both financial institutions and AML consultants while building out training programs to assist financial institutions in mitigating risk. I am also hands-on in our marketing and have been laser focused on our branding. Blogging has been the focal point and we have assembled a small team of bloggers, which has propelled our brand. Our blog can be found on www.amlproblemsolvers.com.
As a company, we are currently working with a Community Bank in Virginia and assisting them with the establishment of a new Enhanced Due Diligence (EDD) program.
What does your career trajectory in financial crime look like?
In 2008, I took a leap of faith and relocated cross-country to accept a contract opportunity with Citibank to enter the field of Anti-Money Laundering (AML). Even with two years of banking experience under my belt, AML was relatively foreign to me. Facing the indefinite nature of a contract position motivated me to learn as much as I could about the profession and realized that AML is destined for massive growth. I recently chronicled my quest into AML in the story below.
A year and a half later, my contract ended and I ended up relocating to Minneapolis in order to transition into a Financial Intelligence Unit (FIU) investigator position. I spent roughly three and a half years in Minneapolis and left with a variety of skillsets under my belt such as Global Sanctions Screening and Remediation, Grand Jury subpoenas, Enhanced Due Diligence, 314b, among others. In 2013, I was recruited to Baltimore in order to assist a large regional bank in completing a project that was instrumental in addressing key discrepancies found in the institution’s risk management agenda, which was found to violate federal anti-money laundering regulations. Once the assignment was complete, I felt it was time to re-focus and delve into the business of AML consulting.
What is the best advice you have ever gotten?
If you are the smartest person in your circle, then you need a new circle. I believe that it’s vital to surround yourself with individuals that can push you to become the best version of yourself.
What is the worst advice you have ever gotten?
I would have to say that it would have to be the cliché, “Good things come to those who wait.” I believe that the movers and shakers in the world have always been about action and chiseled out their own opportunities instead of waiting for opportunities to fall in their lap.
What would you say are the most important attributes for someone in your role to be able to succeed?
In order to excel in the field of AML, it is essential to have a thirst for knowledge and be willing to learn every day. Money Laundering is similar to the common cold because both mutate on a continuous basis so there is no comprehensive cure. Fraudsters are constantly developing ingenious ways to move their illicit funds in and out of the banking system so it is imperative for us to be proactive in discovering these new tactics and developing action plans to benefit the financial institutions that we serve.
Other important attributes are tenacity and attention to detail. Tenacity comes into play because when a roadblock is encountered during an investigation, it is critical to press forward and find a new method to examine the case. In many cases, applying a new method can unlock additional details that can prove to be pivotal in an investigation.
How has (compliance, investigations, etc.) changed and evolved during your career?
When I began my career in Anti-Money Laundering, the primary red flags that we reviewed consisted of irregularities in cash and wire transfer activity. Now that we are in more of a digital age, financial institutions have made great strides in the Enhanced Due Diligence of their customer base. Even with such advancements, we have electronic payment transmitters that are a looming concern for financial crime professionals.
What do you see as key challenges related to financial crime in your role or in the sector overall?
At my capacity, a key challenge lies with communicating the importance of more stringent AML, EDD and Customer Identification Program (CIP) procedures to boards of directors at financial institutions. In their eyes, the bank is profitable and many have the “if it ain’t broke, don’t fix it” mindset. Case studies reveal that small deficiencies compound into larger ones, which tend to escalate into consent orders and hefty fines from a regulatory body.
In the sector overall, the fact that moving money has become more convenient than ever poses a significant degree of risk. Many electronic payment transmitters allow individuals to open accounts without collecting documentary verification and are allowed to transfer funds globally. Their verification procedures consist of collecting an email address, name, date of birth, SSN and address or zip code. These electronic payment transmitters put banks at risk because in order to receive cash in hand, they must be linked to an account in the banking system. Since 314(b) requests have a notoriously slow turnaround time, finding the source of funds tied to an electronic payment is comparable to finding a needle in a haystack.
What motivated you to become a financial crime professional?
Initially, the misnomer of catching the bad guys is what lured me into becoming a financial crime professional. I had illusions of conversing with law enforcement as soon as I detected criminal bank account activity and watching them place handcuffs on the offenders.
What has motivated me to remain in the field of financial crime is the fact that there will never be a point where a financial crime professional knows everything. There are countless opportunities to expand your knowledge base and it is essential do to so because new intricate money laundering schemes are constantly being introduced into the banking system.
Is there anything that surprised you about your current role?
In working with financial institutions, one thing that has surprised me is that financial institutions often view compliance as a necessary evil. Since compliance generates little to no revenue for a financial institution, the department gets very little respect from a board of directors and in many cases operate with AML departments that do not have adequate staffing in order to properly mitigate risk.
Why did you join ACFCS and/or become CFCS certified?
I actually had a co-worker that recommended the CFCS certification because it covered a wide range of disciplines under the financial crime umbrella. As financial crime professionals, we either innovate or vegetate since the landscape of financial crime evolves on a constant basis. I took advantage of the Black Friday special and purchased the CFCS certification course and am quite impressed with the content I have reviewed so far. I plan on taking the examination in the near future.
What is the most rewarding part of your job?
The most rewarding part of my job is witnessing the growth of Taylor Griffin & Associates AML Solutions from an idea to a team in professionals who are fully entrenched in building the company into a household name in AML Compliance.
I also find enjoyment in taking someone who is at a crossroads career wise and cultivating them into an AML professional over time.