Skip to content
Let’s face it, no one grows up saying I want to be a Compliance Officer. When people first started posing the “what do you want to be” question to me as a child, my first response was ballerina. Later as an adolescent, I changed the answer to lawyer. Well, I never became a lawyer (or a ballerina for that matter). Instead I fell into the compliance industry. My first role was on Wall Street in the early 90’s at Merrill Lynch supporting a team of regulatory attorneys in the legal department. The female attorney who hired me, (and is a mentor to this day), happened to be very focused on the risk of money laundering in the securities industry at a time when regulators were primarily focused on this risk at banks. It was the first time I heard the acronym AML (anti-money laundering).
The nature of the work and the fast-paced life on Wall Street was fascinating. Over the years I held a number of different roles covering equities and options, earning a Series 7 license so I could talk the talk; but I always circled back to AML compliance. I loved what it stood for. I felt like I was helping law enforcement catch the bad guys, especially after 9/11, spending hours upon hours searching suspect names through databases and reviewing clients who traded in airline stocks or options prior to that fateful day.
Pre-9/11 most compliance professionals had the time to spend “following the money,” reviewing files and transactions to root out criminal activity. Post 9/11, most found the bulk of their time spent dotting i’s and crossing t’s, afraid that any oversight would be construed as assisting in money laundering or possibly worse, financing terrorism. Please don’t get me wrong; I am patriotic. I know what the acronym USA PATRIOT (Act) stands for. But at some point over the years, it stopped feeling like I was working alongside the government and law enforcement and instead started feeling like I was as much a target as the criminals.
Fast forward to the present and the many articles and speeches about individual liability. The most frightening for me are the enforcement cases. The Compliance Officers charged were not nameless, faceless people to me. They were colleagues that I worked with – either in-house or through industry groups. They were not fly-by-night Compliance Officers that joined the profession in the last few years as it became a “hot” field. These were people that cared like I did and put in the time and effort. If this could happen to them, then it could happen to me.
The time was right for me to take a different approach to combatting financial crime. I turned my passion for rooting out money launderers at one financial institution to teaming up with colleagues and fellow compliance officers at many financial institutions to help them develop more effective compliance programs. Past experience in these roles, the pain points, the tedious processes, and an understanding of existing systems and limitations, gives me a unique ability to help. I have been in those shoes. I understand the demands. As a consultant, I can make a difference to my former securities and banking colleagues. I can swoop in and assist them with a risk assessment or help them strategize about how to mitigate gaps or perform yet another remediation. I also have the ability to provide input to develop cutting edge technology to address their needs.
My purpose for writing this blog is threefold:
- I want to provide Compliance Officers some advice. Ask for the resources you need. Don’t give up until you get them. It’s important to have someone come in and kick the tires on your compliance program. An independent, objective perspective from someone who has been a Compliance Officer and has seen other programs is invaluable. I was always a huge supporter of industry benchmarking but often I did not have the time (or resources) to use that valuable information to enhance my compliance program. If you are in a similar position, please know that help is out there.
- I want to urge senior management at financial firms to listen to their Compliance Officers. You need to understand the magnitude of the stress/risk placed on your Compliance Officers. Give them the support they need. Don’t forget that they are there to protect you and the entire firm as well.
- And finally, I want to caution regulators and law enforcement about unintended potential consequences. Despite speeches that stress your support for compliance functions, that you only go after bad actors – those involved in misconduct, or who obstruct investigations or completely fail to carry out their responsibilities – the enforcement actions over the past few years do keep good Compliance Officers up at night. Be careful that they don’t question whether it’s worth the 12-14 hour days. We need good Compliance Officers to stay in the industry and keep up the good fight.
