COVID-19 and the Compliance Professional

As we enter the 5th (?) week of Stay at Home due to COVID-19, or Coronavirus, I’ve been reflecting on some of the “Silver Linings” that it has brought. Aside from being able to spend more time with family (of the same household), I believe there are many opportunities that our current situation brings to us as Compliance Professionals.

Time for Education

With the majority of compliance professionals now working from home (WFH) rather than commuting to offices, there is extra time in the day. Keeping the discussion focussed on professional practice, this extra time presents the perfect opportunity to study for that Certification or Course that has been on the “to-do” list for so long. Rightly or wrongly, Certifications play an important role in Compliance - and compliance job postings. Having several weeks of viable “study time” is a rare thing.

I’ve presented some of my thoughts on certifications here

If Certifications and Courses are not of interest or appropriate, there is a wealth of newly released or recent books on Financial Crime and other Compliance subjects. If you need inspiration, you may want to check out a previous post titled 12 Recommended Books Related to Financial Crime.

Whether it is a new Certification, Course, or new knowledge on the subject from a reading, the current situation provides us valuable time that we wouldn’t otherwise have.

Personally I’ve used the time to update the Certificate in Financial Crimes Prevention and Mitigation course ahead of the next cohort in September 2020. I’m also exploring the Financial Intelligence Specialist designation offered by ManchesterCF/University of New Haven; the course outline looks very interesting and covers a number of subjects not covered by other certifications. On the book front, I’m reading “Why They Do it: Inside the Mind of the White-Collar Criminal” by Eugene Soltes.

Time for Career Planning

So often the typical Compliance “9-5” doesn’t allow much time for self-reflection or thinking about the next steps in our careers. Now with many Compliance Professionals working from home, and saving time on the commute, perhaps now is a good time to refresh that resume or consider where you want to go next.

Granted, the current COVID situation has curtailed the number of new job postings or interviews being conducted at the moment. However I would argue that this time allows us to consider both short-term and long-term goals and objectives; if you have a 5-year plan, now is a good time to start.

There are a number of virtual networking events and webinars being held online right now. Take advantage of these and explore new connections and new career tangents (and then revisit my first point on Education to get yourself ready for that role)

Time for Critical Thinking

Alongside Report Writing, Critical Thinking is one of the soft skills that I believe is a core “must-have” skill for the modern compliance professional. Whilst there are many short courses on critical thinking (including on LinkedIn Learning), the current COVID situation and changes in banking practices by the public can serve as the perfect reminder / refresher for the compliance professional of the importance of Critical Thinking.

Some changes may be including but not limited to:

1. Increase in cash withdrawals - it has been noted by many professionals in the field that at the start of any major disruptive event, people withdraw cash as a safety and security measure in preparation for bank closures/inability to use plastic. Similarly, once the crisis passes there may be a subsequent large cash deposit (a return of the withdrawn funds). Such an increase in cash withdrawals/deposits may trigger alerts on the Transaction Monitoring system - whilst this may present as “unusual” for a customer, the compliance professional must bear in mind the context in which the activity is taking place. This is a valuable lesson can be applied to many other situations.

2. Increase in large purchases - With COVID-19 especially, and the subsequent Stay at Home rules limiting (the frequency of) outside travel, individuals are spending more in one transaction. This may trigger as a change in behaviour in a Transaction Monitoring system.

3. Purchases of alternative currencies / precious metals - In many crises, there is a tendency to diversify wealth holdings. Transactions related to purchases of alternative / cryptocurrencies or precious metals may appear “unusual” but may simply be an individuals reaction to the current situation. As always, holistic context is key.

There are many other examples of changes in behaviour created by the current COVID-19 (or other major disruptive) situation. But what do these mean for the compliance professional? It is a reminder that context is key! Compliance professionals should not view customers with a one-size-fits-all lens. What is “normal” behaviour today may not be tomorrow - people change, or react to an outside event.

The key question the compliance professional needs to ask is “why is there a change?” - in doing so, they should think outside of the box and try to consider why a customer may be conducting such transactions. Put yourself in their shoes.

Remember that whilst these changes in behaviour may be indicative of suspicious activity, the vast majority of customers are NOT involved in money laundering or terrorist financing! This is a fact that is all too easy to forget for Compliance Professionals working on alerts that have already passed through several lower levels of investigation and been deemed as of concern; by this point the majority of false positives have (or should have) been weeded out.

In the current situation, many Transaction Monitoring systems are likely to go into overdrive and spit out many more alerts than previously. The compliance professional must remain the steady “human” hand.

Whilst I’ve discussed that Compliance Professionals have the perfect opportunity to take advantage of the COVID-19 situation to develop and up skill their professional selves, I should stress that we are living through an unprecedented event and it is perfectly OK to not do any of these and simply make it through what is a challenging time.