Compliance Is Like A Hospital

Managing a department like Compliance is tricky. I’m not saying anything new, I hope. If it is news to you, then you have some catching up to do. With all of the various functions and subject matter experts, managing the department might benefit from a similarly complex organization that has been managing itself or more than a century longer than Compliance: Hospitals.

Say what you will about the broken healthcare system of the US, it still saves lives and keeps non-compliance to a minimum. How does this happen? Part of it is culture. Many receive the call to the profession because they want to do good in the world. And then there is a respect for people’s expertise. The human body is so complicated, no one person can know enough about a single area to save every life. For that matter, there is a competition to solve the most difficult problems that hinder or kill lives. Lastly, there are serious consequences to the professional who is found to be misbehaving.

Compliance, as a profession needs to do all of these things, but there are things a manager can do right now. Since issues of mindset does not require industry-wide scale of economy to work, a manager should:

  1. discuss the goals of compliance on a regular basis to instill a sense of moral calling,
  2. show respect to employees who know a product, function, business, subject matter better than you,
  3. give freedom to employees to work while holding them accountable for their decisions and actions.

Professionalizing the department this way will make a big difference in finding and keeping the right talent.


About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses. He is the author of the forthcoming book History of Money Laundering: How criminals got paid and got away.


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Three Ways To Becoming A Compliance Professional

For the longest time, compliance officers were people with background in law and audit. These are still very useful ways to get into compliance. Over the past three decade, the regulatory environment for financial services firms have become so complex, compliance officers have started to develop training and credentials more focused on the broadened role their profession has taken. Here are three credentials the industry recognizes.

ACAMS LogoCAMS – Certified Anti-Money Laundering Specialist
A certificate that requires higher education, experience and passing an exam, it addresses the largest work of a compliance department. Additionally, three professional references are required to take the exam. The exam is computerized and takes 3.5 hours. There are 120 question in total. The body of knowledge required to pass the exam includes understanding:

  • how money is laundered,
  • various standards for policies and procedures to combat money laundering,
  • how to develop an anti-money laundering program,
  • how to conduct investigations, and
  • how to interact with regulators.

ACFE LogoCFE – Certified Fraud Examiner
A certificate that requires an undergraduate degree, experience and passing an exam, it cover fraud in all industries, not just financial services. The exam is taken at home or in the office with a Windows based web browser. The candidate has 10 hours to complete and submit the 125-question exam. The body of knowledge required to pass the exam includes understanding of:

  • Financial Transactions,
  • Law,
  • Investigation, and
  • Prevention.

ABA LogoCRCM – Certified Regulatory Compliance Manager
Provided by the American Bankers Association, this certificate requires three years of experience, and exam and a combination of conferences and continuing education credits. The 4-hour exam contains 200 questions and covers the regulatory compliance following topics:

  • Credit
  • Deposit
  • Bank Operations
  • BSA/AML/OFAC
  • CRA
  • Privacy

For all certificates, the profession must maintain membership and participate in continuing education.


About the Author: Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses.
He tweets @MoneyCompliance