FCPAméricas Blog
The Ideal Compliance Officer … as Described by Top Compliance Officers
2.13.2013
FCPAméricas has written about the ideal compliance team. How about the ideal compliance officer?
That person was described today at the 2013 Anti-Money Laundering Compliance Conference organized by the Florida International Bankers Association (FIBA). FIBA’s AML conference is one of the largest, focusing on Latin America and drawing over 1,200 participants from banks and other financial institutions and regulatory bodies throughout the region.
Top AML compliance officers from Citigroup, American Express Bank Mexico, CapitalOne, and other banks offered the following perspectives on the traits that make up a successful compliance officer. As you will see, the insights apply as much to anti-corruption compliance professionals as they do to AML professionals. (Note that the officers also made observations about where compliance fits within an organization, described in this post.)
“Our jobs are quickly shifting to prioritizing risks, documenting how decisions are made, and making sure the decisions are understood by those at the top.”
“Just repeating the regulations is the easy part. Knowing how to implement them is much more difficult.”
“The compliance professional must be proactive, understanding the business and targeting different groups within the organization. It requires someone who is open to communication.”
“Why is a particular line of business getting so many complaints? What are the risks within a particular service? Compliance officers need to be able to dissect this information.”
“The ability to influence and communicate. When you are communicating with the data guy, you need to do so in one style. When you communicate with the sales guy, you need to adjust the style. Same with when you are communicating up or down the chain of authority.”
“The ultimate owner of the risk is the Board. How we share information with the Board is essential so that they can make appropriate decisions.”
“Things are moving so quickly. That which was unheard of before might now be standard. Talking to peers and benchmarking is key.”
“They need to be inquisitive. Persons who recognize that what was acceptable yesterday is not necessarily today. And what is acceptable today might not be tomorrow.”
“They are the people who ask six questions, not five. The people who are not satisfied with the status quo.”
“In the past, if you could recite the regs, it was great. And you need that. But the question now is whether can you articulate concerns, identify risks, and make suggestions on how to improve the process.”
“Someone with great organizational skills. You are like an air traffic controller, aligning risks and compliance messaging.”
“Simplify, simplify, simplify. Risk managers tend to overcomplicate things when talking to senior management and the Board. Their real role is to simplify.”
“You should not think of risk assessments as one point in time. You can’t say, I have this data and I am done. We are always in a state of change. If your program is stagnant for 60 days, then something is wrong. You need to be changing and modifying based on what the data is telling you.”
The FCPAméricas blog is not intended to provide legal advice to its readers. The blog entries and posts include only the thoughts, ideas, and impressions of its authors and contributors, and should be considered general information only about the Americas, anti-corruption laws including the U.S. Foreign Corrupt Practices Act, issues related to anti-corruption compliance, and any other matters addressed. Nothing in this publication should be interpreted to constitute legal advice or services of any kind. Furthermore, information found on this blog should not be used as the basis for decisions or actions that may affect your business; instead, companies and businesspeople should seek legal counsel from qualified lawyers regarding anti-corruption laws or any other legal issue. The Editor and the contributors to this blog shall not be responsible for any losses incurred by a reader or a company as a result of information provided in this publication. For more information, please contact Info@MattesonEllisLaw.com.
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© 2013 Matteson Ellis Law, PLLC
Post authored by Matteson Ellis, FCPAméricas Founder & Editor
Comments
February 20th, 2013 at 5:52 pm
Awesome article!
Only thing missing is the Ideal Compliance Officer also needs to know how to minimize the drama and set the example 100% of the time.
Thanks for sharing Matt