compliance officers

The Value of a Necessary Evil

[Reading Time: 3 minutes]

Over the past few years, I have been polling compliance professionals around the world, anonymously, of course, on how compliance and risk management are treated by their senior management within their organizations.  Consistently and overwhelmingly, the preponderance of responses has fallen on the A side:

The truth is that, whether we acknowledge it or not, a focus on compliance and risk management has always been a hard internal sell.  Although compliance professionals are partly to blame for that, I believe most of the Continue reading →

Say No to Nonsense

[Reading time: 5 minutes]

It has been over ten years since the enactment of the USA PATRIOT Act shone the spotlight over all financial institutions and their AML, BSA, CFT and regulatory compliance programs.

Throughout this time much has been written about the rules and regulations that apply and do not apply to each type of financial institution, the perceived and real threats of non-complying with them, and the dozens of cases in which institutions have failed to meet the expected standards and suffered the consequences.  In the case of MSBs, a lot has also been written about the difficulties they have faced in obtaining and retaining banking relationships, which continue to this day.  Very little, however, has been written by compliance officers about what the world looks like from within their organizations.  Understandably so, one might say, given that it may be inappropriate or, if one believes that there might be adverse personal consequences in doing so, simply foolish.

I do not subscribe to the latter.  I believe the best way to fully understand and resolve the issues is to bring Continue reading →