Written by Anastasia Savvateeva, Senior Compliance Officer and Certified Anti-Financial Crime Specialist.
‘‘How many times can we win and lose? How many times can we break the rules between us?
How many times do we have to fight? How many times till we get it right between us?”
Definitely, this Eurovision 2013 winner song perfectly describe the usual relationship between Compliance and Front Office, whatever the industry and the company. Going from innocent “Jeez’, what’s all this mess” to far less agreeable options, sometimes the rapport between “Us” and “Them” appears to be more of a Shakespearean Montecchi/Capuleti-styled drama.
Yet, this historical division is one of the most obvious root causes of such a hostile attitude. Most of us, Compliance Officers, seldom have had a chance to work for the “Dark Side” prior to our knighthood for the Order of Compliance. We tend to blame Client Relationship Managers (CRMs) and to suggest they do not (want to) understand we need to do business with integrity (with everything this notion implies).
During my experience in various institutions, I have noticed that Compliance and CRMs drastically lack dialog, as if we were speaking totally different languages without any chance to understand each other. But the ability to put oneself in CRM’s shoes is what makes a good Compliance Officer irreplaceable and brings solutions to several concomitant issues.
This ability, though, goes hand in hand with communication skills – and even more importantly – with the willingness to communicate.
But even before that: how do you want your Front Office to know – by heart – the regulatory requirements and their impact on them if they cannot even manage to put names to faces?!
Therefore, tip 1: get acquainted. While this may seem obvious, today, in the Covid-19 era (and any other similar context where no one wants to waste 3 hours in public transport or in traffic jam to come to the office), face-to-face introductions and making acquaintances has become a genuine challenge. Even new technologies are of little help (remember that voice out of the blue on Zoom, without any image?). If the Compliance Team Lead does not do this, take this initiative yourself. It will be much appreciated by the Front.
This step should obviously be accompanied by a short description of the Compliance department and the split of roles and responsibilities. Nothing is more frustrating for a CRM than talking to 10 people that do not work on MiFID before finally reaching the right SME.
Now, communication. Tip 2. It is crucial to avoid speaking “Compliancean” without at least explaining the terms you use or, even worse, “Legalese”. The 3C method – Context, Consequences, Concretely – may be of help to shape your written/e-mailed updates.
Oftentimes, however, I have seen CRMs absolutely lost while dealing with new compliance requirements, while those have been (more or less) appropriately communicated.
Therefore, tip 3. Communication goes hand in hand with training; and not just a faceless milk-and-water e-learning but a face-to-face session (at least via Zoom or whatever your company is using), interactive, clear, concise and…fascinating. Yes, you’ve read it right. Fascinating. As
Confucius used to say: “Tell me – and I’ll forget, show me – and I’ll probably remember, involve me – and I’ll understand”. Take a real-life case, a complex file/situation you have had to deal with, and delve into it together with the CRMs, show them what you pay attention to and why in simple words.
Show them yourself where they can find all the necessary documentation for each situation they may face. Take time to speak to each of them. This small investment will bear fruits and prove to be a high-return one.
Today, no one seems to be concerned or afraid of regulatory fines; even in extreme cases, most of the top management and people directly involved in financial crime activity get away with suspended jail terms or fines, if any. That is why showing your CRMs what consequences they and the institution may face if there is a compliance breach is worth close to nothing; it is too abstract, too impersonal, and does not frighten anyone.
Telling them that you agree with them that compliance is just an administrative burden will help neither; you will only discredit your own job and lose respect.
Instead, show your CRMs how smart the criminals can be – and tell them you know they are smarter. Our own trust and faith in our CRMs capabilities will shape the reality we all want to be part of.
Anastasia Savvateeva.