If you are an Anti-Money Laundering (“AML”) compliance officer or aspire to get into the field, you must display the one key quality that all great compliance officers possess: good judgment. The other skills, delineated below, can be learned through training and experience, but good judgment is the foundation upon which everything else is built. The amount of pressure and demands on compliance officers cannot be underestimated; we live in a time where regulations and regulatory expectations only increase, so good judgment is essential to navigating through uncharted or difficult regulatory waters.
Catt Kabadian- Sinai, a subject matter specialist in Financial Crime Compliance, offers the seven skills that should be possessed to ensure good judgment is overlaid with the necessary skill and expertise.
Understanding Your Firm’s Risks
While formal risk assessments are necessary (and expected), any good compliance officer will inherently know where their organization’s key risks reside. This knowledge can be gained through strong metrics, knowledge of products and services (and the typologies used to exploit them), internal and external intelligence, and plain old ‘gut feeling.’ While few will ever mention the latter, it is a valid tool in a compliance officer’s toolbox. As the saying often goes, where there is smoke; there is fire. Follow your nose and embrace your inner investigator.
While most do not view their regulators, examiners and auditors as partners, in many ways they are and should be viewed as such, in so far as it is appropriate. Regulators, examiners and auditors will often raise issues that you either: (1) already know are issues or (2) shine a light on an aspect of your program that you didn’t know was lagging. While it would be the hope to catch these issues and address them before they become formal matters, the manner in which formal matters are addressed and the accountability you can display to these parties can make all the difference in getting the matter resolved and closed.
Lead by example. As a compliance officer, your colleagues (junior and senior) will often look to you to set your firm’s culture of compliance and help set the ‘tone.’ As compliance officers know, context to any given situation is key. Most of the time, we operate in the ‘gray zone’ and the ‘right answer’ will not be found in a book or manual. If, however, you commit yourself to always acting within a professional framework and ‘just doing the right thing’, most of the time – you will get to the correct outcome for the given situation.
Build a Strong Network
No person is an island on to himself, and that is true for any compliance professional as well. Most of the time, the best way to navigate through issues you are faced with is to pick up the phone and call trusted colleagues within the industry. Conduct your own ‘informal benchmarking’ by tapping into your network of trusted and respected compliance professionals. The strength of one’s network often speaks volumes about the type of compliance professional they are.
Attention to Detail
The devil is in the detail when it comes to day-to-day issues that compliance officers often face. To that end, those that can scrutinize issues from different aspects and issue spot, even if the answer is not readily known, will eventually come to the right solution.
While good communication is key to almost any situation and in any organization, a compliance officer must always be mindful that compliance does not happen in a vacuum. Without business (and our business stakeholders in the first line of defense) we would not have jobs. Being able to communicate and work with business stakeholders is key to how effective one can be. Business stakeholders must believe that they have a competent and responsive second line partner who will advise and guide skillfully. Honest and transparent communications will help foster a strong compliance program across your firm.
Healthy Dose of Skepticism
One of the most important functions a compliance officer will play within the second line of defense is to provide ‘credible challenge’. Understand what is being proposed; why it’s being proposed; how it will reduce or mitigate risk; and if it can be effectively ope rationalized. Another important adage is to ‘trust but verify.’ Compliance officers are often natural-born investigators; a skill that must be utilized all throughout one’s career.
A career as financial crime compliance professional can be very rewarding according to Catt Kabadian- Sinai, who has been in the industry for about 15 years. You’re always learning and you’re always evolving because those who want to exploit our financial systems never rest. This industry is not for the weary, but those who are willing to put in the work can enjoy a lifelong career.