Tom Braithwaite, writing for the Financial Times (6th April 2015), has postulated that the ‘bubble’ could burst on compliance jobs. He has suggested that institutions will just pull out of higher risk business rather than justify the associated compliance costs of doing this business. De-risking is certainly something we are seeing and there have been some high profile cases hitting the news in the UK concerning certain banking institutions deciding that certain types of business are outside of their risk appetite rather than try to mitigate the risks. And as an ex-practitioner this is a stance I, personally, fully support but the fact remains that compliance is a growth industry.
Given the ever increasing regulatory focus, financial institutions have been massively increasing their scope for compliance head count and undergoing programmes of upskilling compliance and AML/FCP departments. One tier 1 financial institution now boasts that 10% of its global workforce is in some sort of compliance/AML/financial crime position. So where are all these compliance professionals coming from? Do the people taking up these posts need to be actual compliance professionals?
We have seen various trends here in the UK. When I first entered this arena some 15 or so years ago, compliance was very much the remit of the semi-retired or the responsibility of the office manager/admin and I can remember attending industry events dominated by women and older gentlemen. The increased focus following the PoCA 2002 saw a glut of ex-law enforcement officers entering the private sector and it became almost de rigueur for these guys to be employed in senior AML and FCP posts. But more recently we have been seeing the whole compliance arena as a considered career path – either by graduate recruits or employees moving from other parts of the business. So what type of person makes the best compliance professional? Lots of people have the appropriate qualities to be employed in a compliance role (good attention to detail, methodical, knowledge of the law etc.) but do these qualities alone cut it?
Aside from some of the more dubious accolades I have heard levelled at compliance officers (the business prevention unit, the fun police etc….) one of the biggest criticisms I have heard is that they do not understand the business – which is surely fundamental to the success of any compliance role. In my opinion, strong candidates for compliance roles would be those who have spent time at the coal face and know the ins and outs of the business that they are tasked with protecting. In fact ICA interviewed several compliance and AML practitioners last year and many of them said that knowledge of the business was key to the success of their roles. Compliance roles may not be a sexy as front office roles (and certainly don’t lead to much in the way of seasonal ‘thank yous’ from clients) but they are vital to the success of firms. It’s important that they get the right people in situ which is why I have been pleased to see increasing numbers of delegates from client facing and operational roles attending our workshops at ICT with a view to a career change, or those who have recently moved into a compliance role from another area of the business. If firms are going to bolster their compliance departments to the extent we are seeing, the pool of available talent is simply not there, so it makes sense to recruit from within and invest in appropriate training.
More information on ICA qualifications for new starters or experienced practitioners can be found here.