AML compliance officers and MLROs must make sure that the business activities of the organisation are carried out within a regulatory framework. To accomplish this, the compliance officer must possess a defined set of skills and expertise.
We originally published this list in August 2018 but in October 2020 we put it out to a survey of KYC360 users, asking you to tell us which skills you thought were particularly important. Hundreds of you answered, so thank you. These are the results, in order of importance, as well as some of your other suggestions as to the most important features needed to be a good AML compliance officer.
Integrity is a must for any profession. Regulation management process can only be implemented and achieved effectively if the officers have strong moral principles and honest qualities. But it’s not just enough to know what the right thing is, it’s about having the courage of your convictions; the confidence to speak out; the determination to see things through. Courage was mentioned again and again by survey respondents, along with resilience, strength and developing a ‘thick skin’ – suggesting how daunting a job in compliance can sometimes feel.
The reassuring aspect is that you’re not alone – thousands of AML professionals are in the similar positions. 99% of the time you’ll know in your gut what the right thing to do is to fulfil your professional, and ethical, requirements. Finding the courage to carry it through is the next step. And the right one.
KYC360 itself wouldn’t exist if there weren’t an ongoing need from compliance officers to keep abreast of industry developments. As well as keeping on top of relevant regulatory requirements, professionals should also stay up to speed with the latest tactics and trends in financial crime and money laundering. Criminals are always going to move fast, so to some extent we’re playing catch-up, but we need to keep trying. Never give up.
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It’s not just industry or regulatory knowledge, that’s important. Many of you mentioned the importance of taking a world view on situations, and encouraged compliance officers to be well-networked and globally connected
Risk assessment is a vital component of the compliance function. It is important that the compliance officer takes into consideration all the factors that contribute towards risk scoring, and understands the implications of those risk scores for wider business decision-making.
In the survey, you reinforced how important it was not just to understand the risks you were involved in assessing, but how to balance commercial and regulatory risks (and sometimes personal vs business risks). Being able to consider the risk impact of your work in a wider commercial context is invaluable, particularly if you’re aiming to persuade colleagues of a certain course of action.
Written and verbal communication skills are vital. The compliance officer must have the ability to communicate at all levels in the organisation so that they can share relevant and comprehensive information at the appropriate times. Skills in negotiation (or diplomacy!) can also be useful, and with an approachable manner and a listening ear people won’t be afraid to ask you for help or advice about issues that may be significant.
With regulatory requirements changing rapidly, it is crucial that the compliance officer pays attention and understands them in detail. Requirements may be different between jurisdictions; screening tools may have differences in the parameters they apply; suspicious entities may operate under multiple aliases. Whether it’s the technology, the data, or the law, you’ll need to have a good eye for detail.
Effective problem solving demands a blending of creative and analytical thinking. Compliance officers face the problem of unclear and obscure regulatory policies, cost issues and so on. The compliance officer should be able to identify the risk associated with particular policy-making so that they can draft a simple structured solution.
It helps to actually enjoy solving problems, to be curious and inquisitive about new situations and to be open-minded about possible solutions.
Not all the rules out there are black and white; there will sometimes be grey areas and the ability to create sense and policy out of these can be very useful. Logical analytical skills and critical thinking are valuable – as is (of course) common sense, and sometimes a sprinkling of scepticism…
Last but by no means least, a compliance officer should know how to manage conflict and handle dissension, as there will be times where they may encounter circumstances requiring them to explain and defend their point of view. They should also have confidence and resilience when faced with tough situations and dealing with external agencies such as regulators – as well as when handling internal conflict.
The skills to confidently assert yourself and carry out your job professionally are vital, but don’t neglect your softer side. Being approachable, collaborative and demonstrating good emotional intelligence with your peers and colleagues (both above and below you in the ranks) will stand you in good stead.
Although these attributes are weighted here, many respondents felt that they were all important. Indeed, it is hard to imagine how a good compliance officer could do their job well without needing skills across all eight areas. But if that’s not enough, there were some other key aspects that many of you felt should be highlighted:
* Support from the top – It can make all the difference to your job satisfaction if you feel truly supported and empowered by senior management. We all know how miserable it can be if you feel you’re fighting internal forces in your effort to do a good job, with integrity, so ensuring you have your boss’s or board’s full support is invaluable.
* Patience … or persistence / perseverance …. Or all three. Overseeing AML compliance work is not a job with quick wins or one that often delivers immediate results. The fight against financial crime is waged with many tiny decisions, and you may never directly see the impact of your actions. But take heart, as it’s a job worth doing, in particular, if you:
* Love your job. You’ll rarely get the bonuses of a salesman or the applause of an actor. But that’s why discovering your own satisfaction in your work is so important, whether it’s through well-completed SARs, smoothly managed regulatory inspections, or improvements to internal processes that free up time for your team to concentrate on delivering an excellent client experience. (On that final note, KYC Global’s RiskScreen software is loved by our customers for its easy-to-use interface and up to 95% reduction in false positives – click here to set up a demo!)
Thank you, once again, to everyone who took part in this year’s AML compliance officer survey. For those new to the job, we hope this has been of help. For those already in these posts, we hope it reflects your reality with reasonable accuracy. You’re doing a great job.
By Suresh Chavali (August 2018), updated by KYC360 staff December 2020
This article is expressing personal opinions and is meant for information purposes only. The article does not intend to replace professional or legal advice. It is recommended that readers seek independent professional or legal advice, or speak to authorised persons/organisations.