The Association of Governance, Risk & Compliance
Our panellists were:
- Julie Ampadu, Director, Association of Professional Compliance Consultants (APCC), UK
- Bev Robertson, Chief Operating Officer, Association of Professional Compliance Consultants (APCC), UK
- Samantha Sheen, Founder and Director, Ex Ante Advisory Limited, and Associate Fellow, RUSI, London, UK
- David Symes, Managing Director, Compliance Recruitment Solutions, London, UK
Mateo Jarrin Cuvi: Welcome to AGRC’s latest webinar. This one is co-hosted with the Association of Professional Compliance Consultants (APCC) and we are discussing something that is a very near and dear to our hearts: Building a career in compliance. So this should be good for people who are new to compliance, people who are looking to get into compliance, people who are looking to jump on a career change, etc. So before we get started with our four panellists and our eight questions, let me get some admin issues out of the way. This webinar is being recorded. We are going to have a full video recording available within the next two weeks. We will also have a transcript. Also, if you have any questions for our panellists as you are listening to what they are saying, feel free to drop a question on the chat or using the question function on Zoom and I will try to incorporate those questions into the discussion. I will be moderating on behalf of AGRC. So without further ado, I am going to ask each one of you to introduce yourselves. I will start from the bottom up as I see you on my screen so Sam do you want to please get started.
Sam Sheen: Hi, my name is Sam Sheen, I am originally from Canada. I have worked and lived in at least four different jurisdictions, both as a solicitor and a compliance professional. In my career, I was previously head of an AML division for a regulator and I have worked in a variety of group functions. I currently split my time between advising the European Council and various regulators on their AML compliance regulation activities and advising innovative businesses on operationalizing their compliance activities.
Bev Robertson: Hi, my name is Bev Robertson. I am currently the Chief Operating Officer at the APCC. Previous to that or alongside that, I was an independent compliance consultant for the last 18 years in general insurance in the UK and previous to that I spent my whole life in insurance in some shape or form, having started very long time ago as a very lonely compliance person in an accounts department. So that is where I very first started.
Julie Ampadu: Hello everybody, good afternoon. My name is Julie Ampadu. I am the new chair of the APCC, working closely with Bev. Also, alongside that, I am a practicing compliance consultant and regulatory compliance trainer. Prior to having my own business, I have worked in compliance for about 15 to 20 years, moving from role to role until I took the decision to set up my own business.
David Symes: David Symes, I run Compliance Recruitment Solutions across the UK, Europe and internationally. I originally went into compliance as a young accountant, literally the week that regulation first came into force in the UK, which is almost 34 years ago. I became deputy head of compliance for a FTSE 100 group, which is now part of AXA, then went into recruitment, so I guess I have been recruiting or advising on compliance careers for 34 years.
Based on your experience, is there a specific educational background that is required or preferred when it comes to developing a career in compliance?
Bev Robertson: So I have a very short answer to this one and my answer, I feel, is: No, I do not think there is any specific background or parameters from an educational perspective that people need to have come from. I think it is definitely a career you can go into more or less at any stage and then build out from there. That is my personal feeling about this.
David Symes: I have a longer answer. There is definitely a split here. If you look at, as we say in the UK, the city of London, which is mainly sell-side investment banks, stockbrokers, or buy-side fund managers, they normally expect a degree. They will even look to take graduates on as trainees and American firms will always insist on it because to them it is a graduate profession at any type of role in financial services. Having said that, if you look at the retail sector’s life and pensions, most types of insurance, it is more about the experience, so they do not insist on being a graduate and if you have got some previous work experience in operations, admin, sales, then that counts equally valid. The only problem is that you then move up the company or you try and transfer companies, and you have not got a degree and that becomes an issue. But, for instance, one way around that is to do a master’s level qualification in financial regulation, then no one in HR or board level can say you are not a graduate when you have a master’s, so that will be my answer to that one.
Sam Sheen: I would say, in some respects these days, you need to be a little bit of a hybrid experience wise, which is to say an accountancy degree can be super valuable as can a law degree. But also degrees that require sort of non-linear thinking, mathematics, analysis, if you are inquisitive, if you have any investigation background, if you have been to tech college and you have got particular skills around, even things around IT, super helpful these days. I think the main thing I would say is sometimes it is less about the qualifications you have and they are often asked for. What I tended to find, the failure was when I was interviewing candidates, is they would have all these great paper qualifications but they could not explain to me about what skills that meant they were bringing and how I could benefit from them.
Julie Ampadu: From my experience, all of us work with many firms and have worked with many firms across our kind of lifetime in financial services, but clearly there are different sectors. So within the sector that I have worked in the most, the retail sector, I agree with David, it is about your skill set, it is about the qualities that you bring to the role, and if you have the right personal qualities, right personal characteristics, you can learn the knowledge. It is not difficult. So you can do the learning on the job, you do not have to be a graduate, you do not have to have studied at a higher level once you have left school. If you start with the right company, they will develop you, but you have to have the right character in the first instance. That is my experience.
What are the common assumptions that people make when they think about what it is like to work in compliance?
Sam Sheen: So my area of expertise in compliance is financial crime prevention, and I think the biggest assumption people make is you are going to do all the sexy stuff as soon as you walk in. So you are going to be right in there, investigating money laundering, terrorist financing, and in actual fact, you may in a small place start off like that or you may start off reviewing lots of transactional data, or you may be asked to review policies and procedures. I think it is in some ways assumptions people make about it is it can be super exciting and they do not realize sometimes you have to put the hard yards in. But, conversely, depending on the kind of business you are in, it can be really interesting. Whereas a lot of people get turned off thinking in our area, “Oh, I’m never going to get to see some interesting stuff,” so in some ways it depends on the firm you go to, but it is really important to ask the right questions because sometimes people make very broad assumptions, they arrive at the job on the day, and they are terribly disappointed
Julie Ampadu: Yeah, I totally agree with everything you have just said there. In terms of my view on this, the common assumptions that people make about compliance is that it is a tick box exercise. You are doing lots of checking, lots of templates and forms to say that you have done something right or you have done something wrong, and in my view, that could not be further from the truth. So the real essence around being in compliance and working in compliance is you are working with people and you are influencing people, so, yes, the paperwork’s part of the role, but that is a very dinosaur-like, old-fashioned way of looking at what compliance used to be many years ago. It obviously involves, as Sam said, lots of analytics and interrogation and investigations, and you can make that as interesting as you like depending on your particular passion, but actually it is about people and working with people, so that is my personal view.
Bev Robertson: I would only reiterate Julie’s point there. I absolutely agree that certainly in the sector that I am in, the retail general insurance sector, people do not actually think it is terribly sexy. They think it might be better to become a lawyer or something far more grandiose, and compliance is a little bit further down the order of career choice. So we are, as an association, working really hard to get that message across, that it can be a super interesting career choice. But I think the key for me is that compliance is just one element of this job role, and I think to be able to have that relationship with clients and to be able to go in there and talk to them on an easy-to-understand level and not make it this tick box exercise of just churning out papers from the regulator is a real key skill that people need to have.
What sort of personality traits and skills are necessary to succeed in the field of compliance?
David Symes: The first one is to be diplomatic but still resilient and tenacious. Your employment as a compliance officer is to protect clients and customers but also to protect the firm from reputational damage, fines and that they are closed down. So when you come up with a point, you need to get that across, you get it across firmly but, where you can, diplomatically. If you are stopping someone who had a new product idea that can affect how they view you in the future, it can affect their own feelings about work, it can affect their promotions. When you are stopping a salesperson or a trader from doing a trade, that can directly affect his immediate commission or bonus, but ultimately, you have got to do your job. But if you do it in a nice way, if you tell someone, “I’m really sorry but at the end of the day you know that’s not going to happen,” or if they’ve made an error when they’re the operations manager, you explain it nicely, you try and mitigate how you put it in any written report, they’ll have more respect for you in the future and you’ll do your job better.
The second point is commercial, and it is to recognize that ultimately the firm needs to make a profit. The worst type of compliance officer I used to work for, I am afraid, stops every new initiative on the grounds it may cross the line, it may be against the rules, therefore you should not do it. But if it is expanding into a new country, if it is developing a new product, the best compliance officer understands the commercial viewpoint, looks at ways that he or she can put protection around the idea to stop it crossing the line, rather than just say no cannot happen and move on. So the more you understand the business and the better you understand the need for the business to still make a profit, the better you will do your job and the more you will be respected.
Julie Ampadu: So my take is that, yes, you can teach knowledge and skills. You cannot teach somebody’s behaviour, so their character and the integrity of the character is absolutely crucial, first of all. Secondly, you need to have in your plan a way or a means of developing your interpersonal skills. You are probably the firm’s biggest external influencer, aside from their legal advisor and their accountant. So we need to be in a position where we can comfortably and with confidence be able to influence boards of firms, senior managers, senior individuals within those firms. We are essentially our clients’ critical friend, we have their back and we are trying to protect them and keep them safe, if you like, from enforcement action. But not only that, we are trying to help them create excellence in their firms. So essentially, we are like the Jiminy Cricket on their shoulder, we are almost like an informal non-executive role. We are the ones who go in and challenge the board and who go in and ask them questions that nobody else will dare to ask them. So we have to be able to do that, as David said, in a way that they are going to find acceptable and believable, because if we create challenge that they are going to listen to, then they are really going to think about why we are asking the question as well and why it is important that they think about the things we are challenging them with.
So, yes, if you are going to do anything now, it would be to develop your interpersonal skills. We have within the training and competence area of compliance in the financial services, we have brilliant training and development in terms of knowledge, whether that’s product knowledge or technical knowledge, regulatory knowledge, whatever it is, but we are extremely poor in our interpersonal skills, our leadership skills, our management skills, our negotiation skills with clients, our report writing, presentation skills, we are incredibly poor. So if you are going to focus on any particular area now, there are all sorts of ways you can develop these areas, then that will be something I think is absolutely crucial for building a career in compliance.
Bev Robertson: I think one of the key skills a person can have is to think. At some point, you work for the regulator, you basically have to be the regulator for the firm, for your client, and I think it is very important to be able to have that skill that cuts across, both as David said, you are that firm’s ears and eyes. But for me the biggest thing, I would say, is that a younger person in compliance is to absolutely make sure that you are self-developing all the time, you can do this managing conflicts, managing difficult people, being quite thick-skinned, because as the person with the shield at all times, you are fighting fire from both sides, so it is to have that ability to cope with that pressure as and when it arises.
Sam Sheen: I think everything said is grand, so I am also going to look at it from innovative compliance functions. So for financial crime, there is a lot of movement right now in the crypto industry and a lot of fintechs, and I would say there is three things that really matter: one’s adaptability, one’s responsibility, and the other one is candour.
You will not have a set routine if you go into an innovative business as a compliance person, and you will have to be ready for big radical changes that happen, so things you build, things you design may have to be scrapped and started again or go in a different direction, and you cannot be precious about these things. Equally, your boss probably has time for an elevator pitch description of something, do not write them a 20-page report. You have to be really intuitive to know what is acceptable.
Second is responsibility. The comments and the options that you offer can make a massive difference to how a business operates, so you have to remember, people will rely on exactly what you have said and they will go and act on it, so you must be absolutely sure that your interpretation of requirements is correct, and you take the time and you check it and that is almost an integrity thing.
That leads to my third thing, which is candour. I have seen too many people in this profession with a chip on their shoulder who think you are Robocop even at the medium level of the compliance function. If you go into an innovative business, you will be eaten for lunch if you take that attitude in. Your job is to be able to stand up, be tough, put your big girl pants on when it is time for a debate, but you must be honest, do not exaggerate. If you do not know, say you are going to find out, but just having the title of compliance officer does not mean you get respect off the bat.
What if I want to work in compliance in another country? What should I be thinking about when developing my compliance career to make this possible?
David Symes: This is mainly focused to people in the UK looking to expand. I will leave AML, which is obviously very transferable. Compliance is less so, but certain angles of compliance are. For instance, on the buy-side fund management, both the products and regulation, they are very similar between the UK, between Dublin, and between Luxembourg. Most Luxembourg offices will work in English. They still prefer you to speak French if you can just because it makes life easier when you live there, but if you understand UCITS, fund management, you can move between Ireland, Luxembourg, Britain, no problem at all. Otherwise, the rules tend to be different, but I will come to the Middle East in a moment. But, in generic terms, one way if you want to expand a career outside of your immediate country is to, for instance, American banks may have an international monitoring team, the British banks will have an international compliance monitoring team, volunteer to be on that. In the days of Zoom, it is a bit different but when life goes back to normal, you are visiting the countries, you are getting to know the staff there, you are getting to know their products, you are getting to know their regulations and their culture, of course, even just working on overseas advisory projects can help. Or finally getting a secondment so that when to start Dubai, for example, when banks first started opening in Dubai nearly 20 years ago on the offshore regimes there, sometimes they, instead of recruiting somebody new locally, they would send one of their own people out there because, although the regulations were slightly different, the culture was very different, they’d rather send a known person into a different country, different time zone, who would be on the ground, but they knew him or her and they could trust and rely on that person and then backfill that person’s role in London, for example, rather than recruit somebody completely new to the company in the new location.
So I believe there are some people from the Middle East on this call so just a word on particularly the Gulf, which I call the UAE, which is Dubai, Abu Dhabi, and Qatar. I watched these regulators when they were being set up originally in Dubai 20 years ago, then Qatar three to four years later, and it was the former head of the UK IMRO regulator, which was the fund management regulator before the three regulators were merged 20 years ago, he went out to Dubai, later Qatar, and set up their conduct of business rules strictly along now UK FCA COBS. So it is not impossible for Brits to go out to the Middle East and stop straight into a middle management role out there because the regulations are similar. Twenty years ago it was a lot easier because no one had the local experience. Now it is harder because a lot of people on the ground, not so British expats, have got that experience, so they do not necessarily need to look to Britain, in particular, Australia, New Zealand, to bring people in like they used to. But it is still possible. I have had a recent requirement in Dubai looking for someone at a senior level up to speed with British regulations. They were willing to bring them up to speed with anything local it needed to be.
Sam Sheen: First, I would say is, do your research. It is not as easy as you think to move countries. Sometimes your qualifications are not recognized, whereas in other jurisdictions you can easily slip in and they are worth their weight in gold. So do your research first in terms of the country that you are interested in working in, see if you need to take specific exams, or certifications or qualifications, you might need to do top-ups.
That is my next point, which is be ready to invest the time and money. I am sure David would agree with me, gone are the days when you used to get lovely packages and your entire relocation would be paid for, cost of living adjustment and, boy, what a sweet deal that was. There are not a lot of those anymore. It may be the case that you are going to have to invest in relocating there yourself, maybe doing several flights or trips when you are allowed to do that again, to go and see where you would live, see what the industry is like, have some coffee with people before you really launch yourself into that search, join an association that is active in the region or the country, start to get to know what sort of things they talk about, what things that matter in the compliance community, and really do your research to find out have there been recent laws passed that are relevant to the area. So European AML regulations are not the same as American, for example, and they are not the same as Canada, so it is really important you do not walk in and presume that everything is the same.
My last two things are network, network, network. Most of the jobs that I have received started off with networking with people in other countries, people I kept in contact with after I moved to different countries. Your network is really valuable, cultivate it. And last but not least, have your pitch ready. When you are moving to a jurisdiction that is not familiar with you or your career, it is really important you do not force them to hunt through your CV to understand if you match with them or not, and that’s why cover letters are really key, if you are going to work internationally, is to be able to explain what was relevant about your experience that, despite not having a local qualification, makes you the perfect candidate for the job. So really kind of trying to line it up rather than say to them, here, you figure out how I can be valuable to you.
What is the role of an organization such as APCC in promoting compliance as a viable profession for recent graduates?
Bev Robertson: I think between Julie and myself we could talk about this for several hours. So the APCC, it is such a broad church in terms of compliance consultants who are our members. We reach basically every sector of the UK financial services, but education is something that we are very much focused on certainly in 2022, and Julie can talk about, she is currently chairing our newly formed education working group. Now this is not purely aimed at graduates, this is across the board, hence, why at the very beginning, when you were asking about qualifications, my answer was no because we are at the moment doing things like speakers for schools where we are trying to get people who are leaving school to come into compliance as a career. We are also trying to encourage apprenticeships in this at T-levels, which are the new education settings for people to come into compliance. So there are lots of different avenues at the moment, as well as obviously leaving and going into a graduate program, so I think to say that is high on the APCC’s agenda is an understatement but it is very much work in progress. So it is for us, we certainly have not been asked by the regulator to help them address the shortfall in younger people coming into compliance, it is not that great sexy industry in the UK, certainly in London there are so many other career choices, so we have a tough brief to fill, but we are definitely working on that. But for me, I have not been in the industry for 20 years, I think it has been a fantastic career choice, and one that I think anybody coming out of university should really focus on.
Julie Ampadu: Our educational working group has previously been running for about three years as what we called an apprenticeship working group. So we are working really hard with various institutions to try to create a formal career path into compliance. The UK universities, now alongside all of their academic routes to their degree qualifications, for example, they have to now offer the equivalent of that in an apprenticeship, and what an apprenticeship means is that you can hit the ground running, not just with all the knowledge but with the skills that you need as well. So you are a fully formed compliance expert by the time you leave that apprenticeship and ready to start to work within a firm. We are still working on that and we have had a real difficulty, but we are pressing forward, we are seeing some chinks in the armour now to focus on this path. But I think if you were to ask a hundred compliance consultants whether they chose compliance as a career and they elected to choose that career from school, 99 of them would probably have said no, and the reason for that is… Certainly for myself, I fell into compliance, I’ve never even heard of compliance before I ever entered financial services, and we’ve done work in schools, and I personally have worked with schools and higher education institutions to go and spread the word and tell people about compliance. We have schools where careers officers have not heard about compliance, so how on earth are they going to point young people or people who are later in life looking for a career change? How is anybody going to find out about compliance as a career? And it is an extremely rewarding career. The scope of it is absolutely vast no matter what kind of interest you have, you will find something in compliance that fits your bag, that really relates to you and you can become really passionate about.
So we are very much in the frame of mind that we now have a workforce of over 50 percent in the UK that are Millennials and Generation Z, which the number of you might fall into that cohort, and actually you need to have be furnished with the right information to help you to get that leg up, to get the step up, to get into this career. So we are also looking at a new initiative as part of the educational working group with Steve McGuiness, one of our other directors, to have a bit more of a social purpose around this as well. So we are not just looking at who is interested and getting people interested who would normally be interested, we are looking at people who are not in such a social environment that they might ever think of choosing compliance, these might end up otherwise being blue-collar workers, for example, and do not see that they have a potentially rewarding feature ahead of them. So we are also looking how to reach those people as well, so our purpose as the APCC is spread into the social fabric of our country.
How important is continuing professional development CPD in a professional’s role in the compliance sector?
Bev Robertson: I would say it is extremely important and one of the key things that, as the individual person, you can own and take with you. So CPD is not necessarily something that would be required if you became a compliance consultant. But even if your employer did not require you to have CPD, you are not in a regulated environment, the one thing I used to always say to my clients who had to record CPD was to own it yourself. This is something you can take with you to another employer, if you change direction, it still helps, and it still forms the backbone, and it is for me, it is kind of a continuous building of your CV. So you just move it wherever you go, so I felt it was a very important area that each person can own themselves.
Julie Ampadu: A number of us are members of other professional bodies within the financial services space that do have a CPD requirement anyway and I think, because of our financial services backgrounds that we have all come from, it is as natural as a doctor or a solicitor or anybody, an accountant, anybody else who is in a profession where you need to maintain your integrity, you need to maintain your development. If you were to go and you had the choice of a surgeon to undertake your operation, would you choose one who had the best original qualification and they have left it there or would you choose the one who takes time every week to just keep their knowledge topped up, the latest techniques, the latest developments in medicine? You would clearly choose that one. Also, it helps you as a consultant to find your path; as I said, there are so many different routes to go down depending on the firm you join, depending on the opportunities you come across and you seek out as well. Do not wait for firms to come to you, your CPD will help you shape your own future in terms of which direction. It might be AML, you might end up being on a board of directors of an authorized firm, you might end up being a non-exec, you might end up working within a larger firm, you might end up setting up your own business. So there are all sorts of different routes within a whole range of different sectors across financial services, so I think it is impossible to imagine for me doing my job without CPD. I am doing CPD every day; every time I am doing a piece of work, every piece of work you are doing for a client, you are doing some kind of CPD, and you can’t not, so it becomes just natural part of your everyday working fabric.
Sam Sheen: I feel CPD’ed all over as a solicitor and then as a compliance person. But in all seriousness, you cannot do this job credibly unless you are up to date and reading tweets does not really cut it. The fact of the matter is that in this profession in particular, people are very skeptical about compliance, particularly in the innovative businesses, where they will say: Are you really sure that is a risk? Are you really sure that is a requirement? It’s like having an interview every time you go into a serious meeting and being able to say, “Well, actually last week this happened, and there was an interesting case, which is similar to our business, and here’s how the regulator answered,” or to be able to say, “Well, actually, there’s a consultation on in about six months, this is going to be rolled out, and it may affect our business or onboarding or the type of clients we can take.” It increases your credibility but it makes you invaluable to your compliance team because you are proactively looking ahead, you’re horizon gazing, you are anticipating what are going to be operational challenges for the business. I also think it stops you being stale, it is really easy to get myopic in compliance and become a specialist of just one particular area, and the reality is compliance evolves all the time. So I like the brain twister challenge of what I do, but you have really got to love the topic to really put the time and effort in that CPD if you are going to get value from it.
How has the compliance function changed because of COVID 19? How will this impact the decision of a young professional to specialize in compliance?
David Symes: A couple of things really. I think everyone else would agree that when you are working in compliance and you want to influence people, which is your job, it is what you are getting paid to do, it is a lot easier grabbing someone for a coffee potentially before or after the meeting. But having to set up a Zoom to try and influence people in public, I think actually doing your job gets a lot harder. I am an accountant by training, I have no idea how you can do auditing and monitoring remotely that easily, but apparently you can.
Final thing I say is, particularly for people coming into the profession, you learn on the job by sitting next to someone. You sit in a meeting and you learn what is going on and you are here, you have been tasked with doing a certain bit of research that you then present, but then you have done that, you are not learning from that. You learn by osmosis, you sit there, you are not formally part of the meeting, but you have not done over here, your colleague on a phone, well that is amazing, can you tell me how that happened. When it comes to the monitoring and auditing, even more so, you cannot learn that over a Zoom or by emails. You go out there with your manager and he or she says, “Right, this is how we do it, you do that, any issues just tap me on the shoulder, ask me how and why we need to change this.” You learn by osmosis, by picking up as it comes to you, not by structured learning. That is how I look at it as an auditor and compliance monitoring person in particular, so I think the sooner compliance officers can work together most of the time, the better for everyone.
Sam Sheen: Wow, you know it has been a really tough two years, I cannot believe it has been two years. I think what I would say is go back to all of our collective comments at the beginning about that skill of resilience, and what I mean by that is employers were phenomenally flexible in the first year in terms of working. I certainly know for some of my clients, they allowed people to split their day so they could work in the morning, take care of the kids doing home-schooling, and then they would continue their work in the evening. Some places were allowing people to sort of start midday and work into the evening, there was very much a sense of people’s mental health and well-being was really important, as was their family commitments.
So fast forward, here we are, the world is changing again, and you are starting to see rumblings again of “Gee, we really need to get people back together,” and that is going to feel really foreign for a lot of people, it is going to feel really odd. So I think it is really important, particularly for compliance folks who have figured out how to do their jobs really well remotely, to have those discussions with your employer. It should not be presumed because you have not gone in for two years that you should not go in, but you should be able to talk through what your concerns are. I’ve heard some people say perfectly legitimate concerns like, “I get so much more done at home because the office is so loud, everybody’s so happy to be there, but I can’t hear myself think.” Where we have other people who’ve simply said, “I’ve set up my lifestyle now so I can take those breaks during the day,” and, well, your employer may not be able to accommodate that anymore.
Then there is the reverse side, which is those of you that are going to stay remote, to be able to work your way up the compliance ladder of career, you are going to have to work extra hard to do that networking inside your organization and outside your organization. So even if it is by Zoom even, if it is calling up folks and saying, “I just want to introduce myself and have a chat with you for 15 minutes,” do not feel shy. Keep that stuff going on because it really is valuable, as you work on your career, to just keep in touch with people, let them know you are still interested, and that you are still around. It is really easy to fall down that foxhole and not be seen for a very long time. So, yes, there is two very different sides of it that I think are going to be very different experiences for people, but really building up that resiliency for what is going to come next and how we need to adapt, I think is going to be really important.
Bev Robertson: I would add a positive that I can see from COVID, if that can be said in the same sentence, is that I do think for how we work, it has fast forwarded the use of tech, and I think that hopefully will continue to have the advantages that it has brought. So the likes of doing this webinar today, if you have decided to run this in London as a face-to-face event, it would have just been so much more time consuming for everybody. So for me to be able to do this kind of thing is fantastic, and I do hope that this continues. I think the negative, certainly for younger people in compliance, the compliance function will always be the same compliance, being compliant is what the regulator brings out. Yes, COVID did bring a lot more regulation with it very quickly, very mad, it was manic, but I think for me, the key thing is, if you are coming out of the graduate program, to get back into the office to be with people. Nobody in their teens or their twenties wants to be working from their bedroom all day, every day. It is not healthy, and compliance can be quite a dry subject. So we need to punch as much fun into it as we can, and I think that can only be done by being face-to-face with people, having those drinks after work, that kind of thing, so I think that it is really important that we get back to some kind of a hybrid model along those lines.
Julie Ampadu: I am doing a lot of work on this at the moment. I have been studying for the last four years, actually extensively, culture, and about six years ago now, I think I spoke at The Shard about this in London, about this whole new generational divide between work as a Generation X, Baby Boomer and the Generation Z and Millennials, and how financial services might hit a wall if things did not change in terms of working practices, thinking, and looking forward to what young people wanted. And so came along COVID around that time as well. I think that what has changed for us, as compliance consultants, for me personally, I have had to have a huge amount more interaction with my clients on talking about things that are not to do with compliance. So our role evolved a long time ago, not just as a compliance consultant but as a kind of business advisor, a business support function, but the firms themselves since COVID, when they’ve had remote staff, then they’ve had to really focus on the long term, about really good and regular communication, not checking in, not having cameras on people’s laptops and supervising them that way, but just checking in and saying, “You know, just I’ll give you a quick call, how are you doing, are you okay,” not on a formal half hour meeting where everybody’s got to be dressed and look good on top. But this whole dynamic and the whole culture of compliance has shifted somewhat based on what the firms had to experience and, of course, this is going to continue with the hybrid model.
So in terms of what shifted, I think there has been a lot more pastoral care that has been needed of our clients and the line managers and senior managers of those client firms with their staff. So as an employee or as a potential employee working in compliance, we also know there has been the great resignation where a lot of people now, not just the younger generation but my older generation as well, are getting up in droves and voting with their feet saying, “Yeah, okay, so this was the only way we were before, but actually we don’t want to do that anymore.” So the whole work life balance, as everybody knows, has come into question. So if you are looking at your current position: Am I in the right firm? Do I want to move on? Well, if you like the firm, you enjoy working with the people you are with, you feel that you can add value to the firm, then think about what kind of conversations you can have with the people in your firm, your line manager, your senior team, what kind of influence can you provide to help them to move in the right direction, so that you’ll want to stay. If not and you are thinking about moving into some other role with some other firm potentially, again really do your research, make sure you are looking for the right kind of firm, a firm that really invests in your development. I think that firms are starting to realize since COVID, that the traditional model, the traditional way of doing things just is not going to cut it for anybody anymore, and everybody needs the right job and the right career in the right firm. So be brutal and challenge the firm. If you go for interviews, ask the right questions in the right way obviously. Do not threaten anyone at your interview, but be inquisitive, and do not be afraid to ask about their social purpose, about their view on ESG and personal development. Do not be frightened of them thinking you are going to be a little bit too cocky; this is your future so you need to be looking for the right kind of firm. So as a consultant and as a potential employee within consultancy, I think things have really changed, taken a real shift on the back of COVID.
Are there any known magazine subscriptions you are subscribed to currently that have helped you with your job?
Julie Ampadu: For me, there is not one specific magazine, it is the industry press in the UK, we have a whole range of industry press, financial services, the FCA, the regulatory updates to which you can subscribe. There’s loads coming out, you can subscribe to those on a regular basis where you will get email updates on all kinds of regulatory areas, and it is all financial press.
I think LinkedIn for me is very valuable because, not only can you access new information about regulation, but how it is being accepted within that sector of the industry. You can see people’s views on what is going to work, what is not, so you are also getting a sense of emotion and direction in terms of how firms are coping and compliance consultants as well, legal opinion. There are lots of different angles you can see through sites like LinkedIn, and there are all sorts of groups on LinkedIn for networking, contributing, commenting, discussing, asking questions. I think we are quite a close-knit group in that respect. Some I do not know you obviously but do you agree with that? I think that we like to help each other, so get involved and learn that way, just see where that takes you.
Sam Sheen: I just think there is an ocean of content out there, I mean truly you are spoiled for choice. I think what I would suggest to you is just invest the time, set aside a couple of hours every week, and read what is out there. Some LinkedIn groups will attach links to really good periodicals. Sometimes you will find great credible websites that have really good information, but I think it is finding a really good source that you connect well with and you understand how things are written. I like reading legal cases, I like reading them raw exactly as they are coming out of the courts. Not everybody likes that, some of them prefer government websites with the summaries on them. So figure out how you learn best, what you ingest best, and start creating your own library.
How has technology impacted the compliance function? Has it made life easier for professionals in the sector or will compliance one day be something that is fully automated?
Sam Sheen: The answer to that is yes and it has for several years now. It has since the early noughties when we were using transaction monitoring tools around financial crime. How is it relevant for people starting their career or thinking about going in? You need to get tech savvy; it means you need to understand basic functionality of tools, you need to understand what the term data means, how information looks when it is ingested in systems for compliance people to interpret. It has made life incredibly easy if you can harness and upskill yourself with those know-how essentials to use it. Otherwise, if you thought, “I will leave that to somebody else,” you have probably fallen way behind, and I think it is less about automating the compliance function and a lot more about saving the time in gathering raw data and allowing for the focus to be better on analysis of what is it that I am looking at. So I would just say, yes, it has been great, but you have to be ready to get some real discomfort, get in there like I did. I took a data analytics course after years of not doing probability, it is probably one of the best investments I ever made. It completely changed the way I look at technology and what compliance should do with it.
David Symes: I am interested in your second question, the one on will technology take over. I think splitting compliance into two halves almost. There’s different aspects, but on compliance or on AML, you have monitoring, so unlike AML transaction monitoring, this can be desk reviews, topic reviews, and I think that there may be grounds for thinking that that could be completely automated. The other side of it is advisory, you know, can we launch this new product, can we do this particular trade, the aspects of corporate finance transaction we need to look at. I think that there is so many nuances involved in this, that all the research may be fed through AI, everything that you need to understand, but the ultimate decision will still need to be a human being making a manual override somewhere. The computer will not say, yes, that product can be launched, yes, that complex deal can happen. There will still need to be that connect, that human judgment at the end of the day.
Bev Robertson: So, that question just kind of made me smile. Even this week in a meeting with the regulator, they actually said, “If we get this right and if we can roll this out in the right way, then we won’t need compliance consultants or compliance officers.” That is never going to happen, and I am very confident, I would bet my mortgage on that. The reason for that is because regulation is a rule, it is a tick box if you want to call it that. Interpreting that rule is a skill, and that will always take relationships, it will always take the person, as Sam touched on earlier, to morph themselves into the firm that they are working for that day. The one thing I always said in compliance is expect the unexpected. So I could walk into one client on a Monday who has got this brand-new product, it is a fintech, it is going to be regtech, and you have to react to that. Then the next day, you might walk into another consultancy firm who has got a completely different need, different requirements, so for me, I am very comfortable that the career of compliance is going to be around for a very long time. I do think there are places that will be automated, reports, gathering different data, and the regulator is very much focused on that with their big transformation data program, but there would always be a place for consultants and compliance officers without a doubt.
Julie Ampadu: I totally agree our role is not going anywhere. In my view, there are certain sectors that use tech a lot more, generally, day-to-day than others, so obviously fintech, payment services type firms, for example, crypto. It is all about the data, it’s all about gathering the right information that’s valuable, that’s accurate, so that the compliance consultant can make the right judgments, and the firm itself can make the right internal judgments and recommendations to the board for what needs to change or where the risks lie, etc. So the data is needed, and I think tech is providing the route for us to obtain better quality and quicker, faster, more current data, but we still need to interpret that in the right way. And we cannot interpret data in a silo either. Firms that do that, I see them making big mistakes, you have to have somewhere in the firm that looks at compliance and the cause and effect and to a holistic degree across the organization, and that impacts outside of that specific area that you are gathering the data on.
One of the first things I said today was compliance is all about people, so it is about our ability to influence people, for firms to listen to our recommendations, listen to our advice, and without that, they just have a bunch of data, so that is not going to give them anything really. So I think that we are definitely here today for a very long time. Plus the fact that we are actually business advisors as well as compliance advisors now, so our role is actually expanded if anything.
What would be your three top tips for a young graduate or someone at a crossroads looking to get into compliance?
Sam Sheen: Number one: Decide what area of compliance you want to get involved with. Two: Put the time in to research what kind of things these jobs involve and be ready to explain why your current skill set can fill those responsibilities. And three: Cultivate a passion for the topic. The best compliance people are the ones that we hire who just show such enthusiasm for the topic, and that is the fit that we are looking for.
Bev Robertson: Compliance is a very small word for a very large industry, so do not be narrow-minded. If you go into something and in compliance you can be a bit like a generalist and then you go off and you branch off into other areas and that might not even be compliance. You can go into group risk, you go into ESG, and it really is a huge career choice. The other thing I would say, as Sam has just said, is do your research on the sector that is right for you. If we all do a job we love, then we are not doing a job. That would be my key takeaway.
The thing as well is, it is also a bit of an employee’s market at the moment, so get it right, get the right firms for you, and make sure that it is going to be what you want it to be. There are a lot of different looking firms depending on the sector, but at the same time, your choice is not a big final decision, it is not a be-all and end-all. There are so many different avenues you can move into from where you might start your career out. So as I said right at the very beginning, I started off as an accounts clerk and then here I am today, so there are many different routes to go through the field of compliance.
Julie Ampadu: I might not have three for you, but first thing is, I would say, there are lots and lots of opportunities for compliance in the UK these days, firms are growing compliance, and regulation is not going away. The role is a fantastic opportunity so that is the first thing, there are lots of opportunities. All you need to do is open your eyes and look for them. The way you do that is to network; like Sam said, get networking, get talking to people, contact us. I cannot think of anybody in financial services sector who is working in the sector who would not be happy to give you a hand to hold, to help you, to give you some guidance, give you some advice. We are all happy to do that gladly because some of us did not have that when we entered the financial services sector. So keep your networking going, cultivate relationships, volunteer to go in and have a chat with somebody, spend an hour with them at the firm, look at what different types of firms do, so you have got to invest yourself in this, and you will find that opportunities will come your way.
David Symes: I have got three tips, two of them for graduates, one for people at crossroads. First of all, if you are a graduate, you have not yet got any work experience, get some work experience in financial services in whatever capacity, admin, operations, sales even unlikely for a short-term role, that way you understand the sector. You will understand some of the products, you will understand the role of regulation, because you will be told in the first day all about regulation, and you will understand hopefully how and why the compliance function fits into the whole piece.
Secondly, and this is a bit controversial because it depends on your financial position, but if you are at university, if you can get intern experience directly in the compliance function, or if when you graduate, you can afford to take three months. Again, networking is crucial for getting the opportunity, that you offer to work for free for three months in a compliance function if you can find that sort of role. After that you are made, every other graduates applying, they may have a slightly better degree than you, but you are the one who has actually done three months interning or unpaid work experience and you will get that job.
Finally, looking at people already in financial services but not in compliance that either are losing their job unfortunately or just have a strong interest in compliance, then get within your existing firm ask for a secondment into compliance. Or take the full-time transfer, even if you have to take the salary cut. That firm knows you, they know your strengths, they know your skills, they know your personality. You already know the procedures, the people, the products, the processes, so you were of value to that firm to move in. That way, if they can move you into compliance, it is going to make you redundant or you can get that experience in compliance internally, you are then valuable to another company. Whereas a real-life example, I will get a sales manager, it could be from insurance, it could be from the city, there are a hundred thousand a year, they have just been made redundant, they tell me they understand compliance because they have been following compliance policies and procedures all their career, and they’re happy to take only an 80 thousand pound a year job to move into compliance. Why the hell with anyone expecting 10 years’ experience in compliance for the eighty thousand or more take someone who has not worked in compliance just because they think they can understand it? So before you become that idiot expecting the world to give you a living, ask internally: Can someone give me some experience in compliance? Let me show you how I can work and I will learn from it. I think one thing the industry needs to do more is to cross-train people with existing financial service experience, whether it is in compliance or within AML, how to move across because we are short of new blood, and people in the industry are a very good source of that new blood.