Tug-of-war among competing Compliance interests


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Veneer of Compliance or the real thing?

By Frank Cummings, CEO of AML Partners, LLC

Like many of you, I pay close attention when Compliance makes the news. Usually it’s bad news. Very bad news. Like the Volkswagen scandal or the Wells Fargo debacle or various other descents into Compliance perdition.

A big story last week involved the parting of ways of Volkswagen and its relatively new Compliance chief—an expert recruited away from Daimler in late 2015 because of her reputation as a tough-minded and highly skilled Compliance and legal expert. Volkswagen—eyeballs deep in a massive Compliance scandal related to emissions testing—desperately needed to chart a new course in Compliance and corporate culture. But that particular experiment ended after one year.

Volkswagen’s statement on the matter disclosed very little—except that the separation occurred “due to differences in their understanding of responsibilities and future operating structures within the function she leads.” Granted, Volkswagen has other Compliance professionals on staff and they are subject now to considerable scrutiny, but one can’t help but wonder what happened behind closed doors.

As a longtime creator of AML Compliance software—a career that evolved out of years of on-site AML Compliance consulting—I pay very close attention to what financial institutions and their Compliance teams want. Occasionally, boards want only a ‘veneer of Compliance,’ a metaphor that describes the preference by some to cultivate only the thinnest layer of AML Compliance.

You know the situation: An emphasis on checkbox KYC or an implicit message that profits of any sort are the priority. That kind of tone from the top puts Compliance professionals in an unwelcome position with their superiors and with their colleagues in the various profit-driven departments—especially in this era of increasing individual accountability when regulatory complaints arise.

This type of tone from the top can put pressure, too, on companies that design AML Compliance software solutions: Afterall, it’s our business to satisfy Compliance colleagues and their financial institutions. But at AML Partners, we decided early on to focus on AML software solutions that support meaningful AML Compliance—specifically, AML Compliance designed to help banks keep criminals and terrorists out of the international banking system. That goal matters—immeasurably. As does the ability of financial institutions to achieve AML Compliance effectively—and efficiently.

To that end, we design AML software solutions that support AML Compliance teams and their institutions to operationalize their stated good intentions for Core Compliance—for AML Compliance vastly more robust than a thin veneer. Moreover, it’s an approach to Compliance that transforms a best-practices Risk-based Approach into a digital powerhouse that analyzes risk with a fine grain—not a broad-brush de-risking approach.

Our customers design their own workflows, create their own risk models unique to their books of business, create fully accountable user roles, create their own unique question-collection set, tune their own sanctions-screening system, and define the parameters of their transaction monitoring according to customer behaviors. And every keystroke, every action is archived in an audit system.

This is AML Compliance so much deeper than a veneer—it’s robust, it’s configurable to the nth degree, it’s an individual institution’s Compliance intentions captured in finely grained detail, enacted to make the work both effective and efficient, and digitally tracked for full accountability. It’s AML Compliance that helps keep criminals and terrorists out of the international banking system—and helps banks pursue their business goals while achieving their Compliance goals. All of those things matter—immeasurably.

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