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What makes an effective compliance officer?

Ken Rijock, Compliance consultant, Miami, 14 June 2021

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This poster, circulated to entice Americans to enlist in NASA for its push to explore and eventually colonise Mars, could easily apply to compliance officers. More than anything else, the financial community needs compliance officers who can discharge their duties with enthusiasm.

What, in my humble opinion, makes a good compliance officer? Here are my thoughts.

1. An effective compliance officer must be a renaissance person. This entails a good liberal arts education which exposes him to not just history and geography but also to language, technology, and yes, even literature, to be able to meet the challenges that he faces daily. It is not always worth moving someone over from another division at a bank to become a compliance officer if he does not already have a well-rounded education as a foundation. Compliance officers must be explorers of information.

2. A good compliance officer is not afraid to take on customer relationship/business development/sales staff, when their need to generate new business is trumped by genuine compliance-related concerns.

3. A compliance officer/money-laundering reporting officer knows the tradecraft, the actual methods and tactics, of financial criminals, especially money launderers and fraudsters. If a compliance officer does not know how crime works, he cannot spot it and stop it in real time.

4. An effective compliance officer has a good relationship with both in-house counsel and the external lawyers who advise his bank. When potential compliance issues come up, a good lawyer on the compliance officer's side can make the difference between him winning and losing his argument with his superiors at the bank who may be more intent on maximising profits than on compliance.

5. Finally, a truly great compliance officer knows where to go for reliable sources of non-public information and never relies strictly upon commercial off-the-shelf data when making major decisions.

Let us remember that an effective compliance officer never simply ticks the boxes; he always looks further than the law requires him to look in order to obtain the answers.

Explore away!

* Ken Rijock can be reached at miamicompliance@gmail.com

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