June 18, 2024
There are wars in the Middle East, in the Ukraine, parts of Africa and yes there is too much fraud, money laundering, terrorist financing and proliferation financing going on that needs to be prevented. But we’re not in the trenches and our lives are not in danger, certainly not in the 2nd line-of-defense. Where it really matters is in the 1st line-of-defense.
Let’s talk about what is important – based on our experience and expertise:
It all starts with awareness, about the financial crimes which often look harmless. The underlying predicate offences which include modern slavery, drug and arms trafficking, corruption and more activities that no human being in his/her right mind wants to be involved in are far from that though. Just have a look here to get an idea https://www.tookitaki.com/compliance-hub/6amld-predicate-offences. If all people really knew where the money in their accounts came from and how it was generated they’d be more interested in preventing financial crimes. Maybe it’s too ambitious to raise that awareness across society at large, but at least all staff in financial services (and businesses closely related to financial services) should be aware of the financial crimes, the underlying predicate offences and basic actions to take in preventing them.
The second crucial element is operational compliance – meaning that every person in an organisation adheres to the policies around financial crime prevention. Issuing policies and raising awareness is not enough. Organisations need to ensure staff implement these policies in their day-to-day work. On-the-job-training, the right Tone-from-the-Top, proper procedures, operational control and risk management are needed for that. Many regulations and policies are in place for a long time but speaking at seminars or additional ‘tick-the-box’ measures are not helping. This article clearly highlights that https://www.straitstimes.com/business/singapore-banks-probe-rich-clients-after-3-billion-money-laundering-case.
Remember: it’s the 1st line-of-defense that stops crime – all relation managers, customer service staff, tellers and operations staff – they do the heavy lifting and make sure the organisation in all it’s actions complies with the policies.
So… at the risk of ‘calling the kettle black’ let’s focus on that. I see a lot of posts from (ex) colleagues, business partners, solution providers, compliance practitioners, random connections and others. We all know that ‘bragging’ is not done, so we ‘humble-brag’ about our own achievements, attendance at seminars, talks as sponsor at RegTech or FinTech fairs and what have you.
Sometimes we manage to post something that might actually be relevant to others: a new product launched, a happy customer, some real-world achievement. But very often it’s just about where we are, what we do, who we meet and not about what we achieve.
So let’s not call ourselves ‘warriors’ even though we ‘fight’ financial crime. We’re not in the trenches, we’re not suffering, most of us have well-paid jobs in a safe environment, so let’s just be honest and realistic. Let’s post only things that are relevant to others, not just about where we’ve been, what tradeshow we attended or what audience listened to us. Most important: let’s focus on where compliance happens: in the front line. Compliance officers set the tone, make the policies and monitor adherence to the rules and regulations. Everybody else in the organisation is responsible for making sure the organisation complies with the policies.
Compliance is nothing more than living up to your promises and that means every employee needs to do his/her part in achieving that operational compliance. Let’s focus on all these people, help and support them and make sure integrity is everybody’s business.