It is bittersweet to share with you that, after more than 20 years serving Corporate One’s Risk Management department, I am retiring on June 1. While I’m looking forward to spending time with my grandsons and family, I promise to keep in touch with the industry I’ve grown to love. Throughout my career with Corporate One, I’ve managed our BSA/AML and OFAC/Sanctions in some form over its entirety. As a sign off, I wanted to share three “top takeaways” I’ve learned during my career.
The importance of people
First, people are THE key. Hiring the right people for the job is essential. Compliance is a tough hat to wear; it sets you up for conflict with forces in your credit union incented by sales and making margin who want to keep that member who is a subject of your SAR filings. You must keep information confidential, even when it might be useful to someone making a credit decision. It potentially puts you in the possession of information about your own members that could be used inappropriately in your own community.
Today, with hiring so difficult, my advice is to be cautious, and do not be afraid to own up to that mistake should you make it. BSA/AML and OFAC/sanctions compliance done wrong can cost your credit union money (fines!), the burden of added regulatory scrutiny, and (especially) your reputation.
The importance of trusting yourself
One of the difficulties in AML and sanctions compliance is the routine nature of the job. It takes a special person to process thousands of alerts without zoning out. It is easy for something suspicious to be made to look routine and acceptable through sheer repetition (think ACH, the epitome of repetition). Instead, follow your process and procedures but keep that process informed by the dynamic field we operate in – typologies change, favored fraudulent payment types change, the economy changes, and regulations change.
While BSA/AML staff need to ensure that alerts are managed every day and timely reports are filed, listen to your gut when you review that alert or the internal referral. So often I have found that spending one more minute to turn over that one additional rock, such as a simple Google search or reaching out to staff to learn how that new product should be used, was what moved me to file that SAR.
And always, remember that you are not looking for “enough” evidence; you are looking for suspicious activities for others to pursue and adjudicate. Don’t overthink it. When in doubt, file the SAR!
The importance of training and education
Finally, training and education are critical. I have been fortunate to work with some terrific professionals after engaging with the Northern Ohio Chapter of ACAMS many years ago. Attending their meetings helped form relationships that led to Corporate One founding our own chapter in Central and Southern Ohio.
Two things really motivated me to drive to Cleveland and engage with the ACAMS chapter. First, training is one of the five pillars of an effective AML compliance program; and second, there is a premium placed on certifications in the BSA/AML and OFAC/sanctions field by professionals and examiners in the industry. Of course, ACAMS certifications are not the only ones out there; CFE and certifications offered within the credit union industry are terrific, as well. My certifications led me to work with the international ACAMS organization as a volunteer member of their Educational Forum, as a webinar host, and recently, as a contributing question writer for the CAMS-Audit exam and recent work on the CAMS-FCI exam.
Most important, continuing education requirements kept me at the forefront of the industry and enabled me to contribute to Corporate One’s compliance program as my roles changed over the past 20 years. I am proud of the policies I have written, the staff I’ve hired and trained, the members I’ve engaged, and the investigations that resulted from reports my staff and I filed over the years. I intend to maintain my certification after retiring from Corporate One and continue to work with my peers in some form, including continuing to serve as the Chair of the Central Ohio ACAMS Chapter.
While my career at Corporate One winds down, email me your takeaways and any questions you may have at jenny.CUPlatinum@gmail.com. And look me up at the Central Ohio ACAMS Chapter. All my best wishes to you in the years ahead!
Editor’s note: All of us at Corporate One are beyond grateful for Jenny’s experience, leadership, and dedication to serving our organization and the greater credit union industry. We wish her much happiness in her retirement and have already added her Gmail address to our contact list! She’s an amazing mentor and expert in the field and we are indebted to her for sharing her talents with us.