Celebrating 10 years! 2007-2017

Is compliance difficult?

I recently started an AML/KYC position with a major bank aft lawdawg10/20/18
It’s very simple: If you keep slamming the business bro dingbat10/20/18
The key to compliance is helping the business bros to get ar dingbat10/20/18
Lol, I don't think that applies to my role. I am basically d lawdawg10/20/18
I know... I once told one of those KYC/AML idiots to go f-c dingbat10/20/18
Always Be Climbing. The two most successful people on this b daveramsey10/20/18
Never said that at all u rat bastard lol. Become a master of esquirewalletsmatter10/20/18
my main takeaway from the interactions I had with compliance dingbat10/20/18
Very astute observation per usual. esquirewalletsmatter10/21/18
lawdawg (Oct 20, 2018 - 9:34 am)

I recently started an AML/KYC position with a major bank after numerous years of litigation. I am using this opportunity to see if this is something I can do in the long run, as I am burnt out from litigation and all the stress that comes with it. I feel very uncomfortable in that everything is completely new. I can't remember how I felt when I first started litigating, since it has been so long, but I am imagine I felt the same way. Does this get easier? For those who did litigate and then switched into compliance, do you enjoy it more? How long did it take you to feel comfortable? Pros? Cons?

Thanks!

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dingbat (Oct 20, 2018 - 10:10 am)

It’s very simple:

If you keep slamming the business bros for violating the rules, you’ll lose your job
If you don’t, you’ll lose your license

Pro-tip: never tell a business bro they can’t do X. Always provide a palatable alternative.
Something along the lines of “You can’t bribe that foreign official, but you can offer his son a job [which is sorta the same thing]”
Oh, and you’ll need to spell out the parts in brackets, because they are that dumb, but you can’t do it in writing

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dingbat (Oct 20, 2018 - 10:11 am)

The key to compliance is helping the business bros to get around the rules without actually breaking the rules

See eg the manafort trial. The only person who went down for money laundering was manafort.

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lawdawg (Oct 20, 2018 - 10:57 am)

Lol, I don't think that applies to my role. I am basically doing peer review of corporations, companies, their owners, etc. to make sure they are who they say they are and that we have all the supporting documentation to prove it.....which is probably a really watered down way of explaining it....

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dingbat (Oct 20, 2018 - 1:58 pm)

I know... I once told one of those KYC/AML idiots to go f-ck themselves.

Then I called her boss, told the boss that the client was already an existing client of their firm, and if they needed any more KYC to just go down the hall to whoever it was that did the KYC analysis last time. The underling called me within 5 minutes to say "nevermind, we don't need that stuff after all"

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daveramsey (Oct 20, 2018 - 2:19 pm)

Always Be Climbing. The two most successful people on this board in that field (fompliance & esquirewalletsmatter) stress the importance of consistently shopping your resume internally and at peers (ie, if at JPM, look to GS or WFB). Its a lot like craplaw litigation where any day over 12 months spent in one position “marries” you to that specific drudgery.

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esquirewalletsmatter (Oct 20, 2018 - 5:26 pm)

Never said that at all u rat bastard lol. Become a master of your craft. Far more complex than meets the eye but once you get it down it’s really just application of the rules. A lot of responsibility but you’re used to it as a litigator. Doing it everyday you’ll know far more than the cut and paste attorneys. Ask yourself how you would launder the funds, there’s many creative ways and it’s relatively simple for attorneys and accountants to accomplish such. Continually learn. Put in the work just like in law. There aren’t that many experts but with your background you can become one.

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dingbat (Oct 20, 2018 - 7:18 pm)

my main takeaway from the interactions I had with compliance was to never stop digging until you got to the start/finish. No matter how many layers of entities, find the individuals. No matter how many transfers/transactions, find the origin of the funds.

It's both easier and harder than it sounds.

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esquirewalletsmatter (Oct 21, 2018 - 2:53 pm)

Very astute observation per usual.

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