Our Global Manager for Partners and Media, Mateo Jarrin Cuvi, was interviewed earlier this year by FinCrime Agent, a YouTube channel that shares tutorials, job talks, conference reviews and interviews related to Financial Crime prevention.
During this discussion, plenty of information was shared on the value of certifications, the type of skills a professional should have to excel in compliance, the role of technology in our industry, and plenty more.
Find below a summarised written version of the event and access to the full video interview.
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Could you please give us an overview of the key benefits of financial crime compliance training when those are rolled out at the executive level?
First of all, we have to actually point out the importance that executives have in shaping an organization’s culture, a culture of transparency, ethical behaviour, and compliance. It all starts from the top; the buck stops with the executive leaders, with upper management, etc., and it is a trickle-down process from there. So , executives have to set the example, they have to set the pace, they have to set the strategies that will allow the company to remain compliant, remain transparent, remain ethical. At the same time, executives have to realize that they are being held accountable if anything goes wrong or if anything suspicious happens and, to prevent this, all the executives must know their obligations to their organizations, regulators and also the stakeholders, and they must also have a thorough understanding of the risks of non-compliance for their organization.
Here is for example something where ESG comes into play. We are talking about environment social and governance issues that are trending these days and a lot of organizations that put a lot more emphasis on this, to focus on governance, to focus on social issues, to focus on the environment, things that stakeholders are really clamouring for, they are asking companies to focus on.
So within this framework, I think it is crucial for executive directors or CEOs or upper management to actually acquire the competence, acquire the training, acquire the knowledge and the education when it comes to corporate governance issues and how to develop appropriate processes. A lot of this is done through experience but it does not hurt, for example, to every so often do a certification, do some training as a refresher or as a way of keeping up to date with what is happening in the industry. So I think, given the responsibilities that upper management and CEOs have, this is primordial, this is something crucial, this is something that it is a win-win situation, to actually go through these trainings as an executive director or CEO, etc.
Which types of certificates or financial crime compliance training courses would you recommend to those that are new to the industry and are keen to develop a career?
Yes, now we are going to look at it from the other level, a recent graduate or someone who wants a career change. What is the use of these sort of certifications and education and training programs? There are many opportunities in this sector, many jobs are being created in compliance, in AML and KYC, onboarding, reporting, etc., on a daily basis. We have the growth of fintech, of regtech, which are growing exponentially in terms of all of these technological solutions that are popping up in the market and, as a result, regulatory authorities are also actually getting in on the game and actually creating a lot more regulations that these companies have to follow. You look at payment solutions and all of the compliance that they have to actually comply with, there are a lot more checks and controls to do these days, thus jobs are expanding in the area. Since there is this expansion, what you start seeing is you have subunits within a compliance function, you have people that specialize in AML, you have people that specialize in KYC or CDD, you have people who specialize on onboarding, on reporting, on monitoring, on all these different issues.
So one way to look at it is, if you want to enter the compliance function, you can strictly focus on AML and become a specialist in AML to join the compliance department for a specific company. At the same time, there is going to be a sort of crossing of knowledge and skills, it is also useful to actually have a comprehensive, a global perspective on everything that entails compliance and, in this way, a professional in this area will be able to actually carry out their duties in a more effective, thorough, and responsible way. So it really depends on what direction you want to take, you could be very specialized, say only specialize in monitoring or KYC or compliance or sanctions or whatnot, or you can take a more global, more holistic approach and do something more general, which would focus on compliance, which touches upon all these other different issues.
Right now, for example, AGRC has certificates in AML, in KYC/CDD, in Compliance, and also in International Economic Sanctions with a focus on compliance. In 2022, we are going to be rolling out certificates in ESG, in corporate governance, and in risk management, so whether it’s with AGRC or with some other association that does similar work, it’s useful for a young graduate who’s interested in these areas to actually wet their feet by taking one of these certificates, which introduces them to this area, provides them with a solid background to actually kick off their career in the GRC world.
I think in combination with that, what I think recent graduates have to do is also focus on CPDs, on continuing professional development. So that means on an annual basis and generally when you are a member of an organization like AGRC, you have to follow a regime in which you actually have to take certain hours of CPD credits on a yearly basis so that will also build your knowledge, build your skills and the tools that you will actually need to carry out your job. At the same time, actively participate in an association such as AGRC, do some networking, follow the news, keep up to date with everything that is happening in the industry, and this is something that an association like AGRC can help a young professional do. So that is the way I see it and the way I would suggest a young professional, recent graduate, or someone looking for a career change to go about it but the opportunities are out there and they are really great in the sector.
For those people that are new to the sector, is there a specific background that may be required to develop a career in financial crime?
I do not think there is a specific background per se. I know a lot of the people who actually enter this sector, they are either going to be lawyers or accountants or political scientists or someone doing a criminology or something along those lines, it tends to work in that direction. But I do not think you necessarily need to have that background. I could very easily see an English literature major deciding that working in compliance and working in financial crime is something for them with the use of communication, language, and whatnot, but in our case, we see a lot of different backgrounds.
There are certain characteristics or qualities that a person involved in financial crime needs to have if you are either going to be in compliance, AML, or any of these sort of sectors. If you are working for private companies, let us say, or for businesses, you need to have a good understanding of a company’s business, its products, its services, its offerings. You also have to have a very good understanding of your company’s role within the larger globe, within the larger scope of things, how does a company fit in the global economy, how it interacts with other markets, etc. You need to have a good understanding of the stakes involved, what are the main risks or the main challenges that are going to be faced by this company on a daily basis, and what is going to happen if these are not handled correctly. Also, you have to, as we mentioned already, you have to keep up to date with what is happening in the market, again you have to be familiar with the company’s overall strategy, you have to find a way of aligning the compliance function with the overall business, you have to understand the potential risks to anticipate them.
So to be able to do this, compliance officers or people in AML and financial crime prevention, you have to be terrific listeners, you have to understand the pressure points between the business and the law, and you are going to have to work with many different departments within a business to accommodate the needs that each one of them have. I will give you an example from my personal experience. When I was doing content for a Forex company, there was always a sort of clash between the marketing department and the compliance department because the marketing department, their goal is to actually get people to trade and the compliance is, “Okay, yes, but you have to fall in with a very strict set of rules.” So if you’re going to be in compliance and you want to carry out that role, you have to be able to convince marketing that, “Okay, you can’t do that, you have to do things in a specific way.” You have to try to influence business so that it works within the lines and sometimes you are going to have to take decisions that are unpopular or that are difficult but that are necessary to prevent any sort of illicit behaviours or illegal activities or whatnot.
At the same time, I think any sort of compliance officer or AML person professional should be skilled at designing simple and understandable processes and procedures, you have to be able to put together a financial prevention plan, an AML plan, a compliance plan that is easy to understand, that you’re going to share with the rest of your organization, and you have to be able to relate information in a clear effective way, that can be actually implemented fairly quickly and easily. So I think these are sort of the things that any sort of person in financial crime has to have but, yes, the laundry list of qualities after that, it really extends but that is where I would see the most important points being.
Since the COVID19 pandemic started, how have certifications and financial crime compliance training in the regulatory compliance sector evolved?
In terms of training, we have to talk about technology first, but I know we have another technology question later on in the interview, so I am going to set that aside. But one of the things that you see for example during the past two years is the number of hacking, of cyber security threats, of cyber security risks that have actually popped up because people are working remotely, people are working from their homes, people have more time on their hands, just sitting in front of the computer at home, because they cannot go out and this that and the other. You have this increase in cyber breaches, I would say, and this is something that companies have had to focus on either by bringing solutions, either by providing more training to their employees, so this is something that I think COVID has actually ramped up and that more companies are paying attention to.
At the same time, during the past five years, what you see is a whole range of different regulations popping up, there is also a lot more automation in terms of the job functions so the level of complexity and the level of knowledge and the level of skills that any sort of compliance officer or AML officer need to have to carry out their job is expanding, it is growing. Just to give you an example from my days back in international taxation, at an EU level right now you have a lot more laws that have to be followed, that are aimed to prevent tax evasion. So we have the UBOs, we have the ultimate beneficial owner registries that are being rolled out in Europe, so that is an additional compliance point that people have to be aware of. In the past you had CRS, the Common Reporting Standard, you had FATCA, you have DAC6 too in the EU. But again, compliance officers have to be aware of these new regulations, they have to be aware of the changes, they have to keep up to date so that they can actually report on these and remain compliant. So this has created a huge need for further training of compliance officers in more areas. So compliance is expanding and growing and this need for constant training, this need for staying up to date, this need for acquiring new skills and tools, it is growing, and education is one way of doing that and training is probably one of the better ways of actually staying compliant and having the knowledge to carry out your duties.
Are the new technologies making life easier for people operating in the education and training space?
I think there are pros and cons as with everything in life, but I do think given COVID and given what is happening, it is much easier now to actually carry out trainings. We have official training partners that do a lot of their training live online or self-paced online, and it is very convenient. You do not have to actually get on a bus or a train or a car or a plane to attend a conference. You sit in front of your computer, you log on to Zoom like we are doing right now, and you take a five-hour course on DAC6 or CRS or something else and, at the same time, self-paced online you could do it in the evenings, you could do whenever you have a break, whenever you have an hour to spare. You can sit down and complete your training so it has actually made it a lot easier for people to get trained and to actually acquire those new skills and tools and knowledge that they need.
At the same time, technology has allowed a lot of organizations like ours to provide more engaging content for users and for their members. Another thing that actually has changed, I do not know if this is a generational issue, but with the new generations of younger professionals, attention spans have actually decreased, people do not want to sit through a two-hour lecture, they do not want to sit through a five-hour course, and time is of the essence. So a lot of organizations have focused on micro-learning or bite-sized courses, 10-minute courses here and there that they can do in their spare time to actually get a flavour of something that they need to maybe build on.
The last thing that I want to bring up here are conferences during the past two years, it has been amazing what organizations have been doing in terms of online conferences. A few months ago, AGRC was a media partner for EQS’s European Compliance and Ethics Conference (ECEC), and I was simply blown away by the level of the quality of the actual conference. They had a yoga session in the morning, so you could wake up, roll out of bed, you can log on to a Zoom-like platform, and you can do a yoga session. Then you would sit down in front of your computer to actually listen to very high quality and very well-respected speakers and you can interact with a lot of the sponsors. It was a very well put together conference and a lot of organizations are doing this, so you are saving money for your company, you do not have to travel, hotels, meals. At the same time, you are lowering your carbon footprint, which is good, so there is a big future for virtual conferences and for these sorts of online events. This, of course, does not take away from the fact that sometimes it is much better to meet in person and actually interact and have a chat over a beer or a coffee or something like that, but I think there’s room for both of these models moving forward.
Which financial crime area do you think is going to expand the most in the next five years?
From my perspective, financial crime is continually evolving, it is always on the move, on the go. Criminals are following the latest trends, and I can see an increase in using technology and cybercrime to achieve their goals. We have seen that with cyber security and all the cyber breaches and hacks and the phishing scandals that have emerged during the past two years with COVID. I think digital currencies is a place that are going to continue to be exploited if you are talking about all the cryptocurrencies that are largely unregulated. I think criminals are going to continue using that just in the same way they used Silk Road 10 years ago, I do not know, that is going to be continuously exploited by criminals. For example, just to give you an example, recently I saw a documentary on Vice on money mules, about how young adults in the UK are being hired via Snapchat to be money mules. They would have money deposited in their account and they would actually extract the money and then deliver to someone, they would get a cut, and all of this is done via social media.
So I think technology is going to be a driving factor. I think cryptocurrencies are going to continue to play a role there. The fact is financial crime is very innovative, they always have to try to stay a step ahead of the game, stay a step ahead of the police and the regulatory authorities, and this poses a problem for the compliance world because it seems like we are always in a reactive position versus a proactive one. So I think part of what compliance officers and financial crime people have to do is try to predict what is going to be the next step, what is going to be the next phase of financial crime to be able to set the tools, then the skills that will actually prevent these things from happening or at least curtailing them to a certain extent. So it is hard to predict but it is a fascinating subject and I am looking forward to seeing what is going to happen within the next five years.