Tips and Triumphs from our Four Compliance All-Stars

And just like that, summer is gone, and with it, Clausematch’s Summer Festival came to an end.

 From July-September, Clausematch hosted a series of virtual events that covered some of the hottest topics for compliance professionals. During our final event in September, we had the pleasure of hosting four compliance all-stars, Evgeny Likhoded, Founder and CEO at Clausematch, Dana Lawrence, Chief Compliance Officer and Advisor at Fideseo, Ada Margaret Ogbeyi CAMS, Lead, Compliance Governance & Learning at UBA Group and Tommaso S., Head of Financial Crime at Currencycloud, for a chat. They shared real-life stories and tips on how to turn compliance challenges into opportunities. Here you’ll find a summary of the key snippets from the webinar but you can access the full content here. 

 Transforming a compliance challenge into a RegTech solution

 Evgeny, also known as Jay, was working in legal and compliance for Morgan Stanley in 2009, when they were having to adapt to a great deal of new regulations. For this reason, he was involved in a lot of regulatory implementation and remediation projects. These projects required that he spent most of his time working with different types of compliance documents, as well as contracts. Back then, he realised that companies had been managing important documents in the same manual way for over 20 years, using traditional tools, such as Word, SharePoint and Excel, and in silos. That’s when he had the idea to create a tool that would fix the creation of compliance documents and centralise it. 

 With this vision, he started Clausematch, aiming to help organisations manage compliance content, such as policies, procedures, and obligations, in real time, in a modern, centralised fashion. Jay’s goal was to develop a tool that allowed companies to have full control over document versions, avoiding back and forth of emails, provided a complete audit trail for regulators, becoming a single source of truth that could be disseminated across the whole workforce, to help drive the right employee behaviour.

 The vision was turned into reality, and now,ten years later, Clausematch is adopted by companies across the globe. Our solution allows them to understand and manage a document’s complete lifecycle, from creation, to update and dissemination, at a paragraph level, with full versioning control. The platform goes beyond that, enabling intelligent, contextual mapping of documents, i.e., linking an AML policy to all relevant procedures, standards, and controls, providing automated alerts for editors and approvers, and reporting capabilities that compliance departments can present to their C-level stakeholders. 

 “We’re on a mission to solve compliance for organisations in regulated industries. It’s been an incredible journey so far, with incredible customers. For many, this world of compliance is not an exciting subject, but we actually believe that solving compliance will help organisations to bring safe products to the market, from financial services down to physical products that need to comply with standards, and make sure that every organisation has got a culture of compliance with their employees”, he concluded. 

 Transaction monitoring for cryptocurrencies

 Ada Ogbeyi, as well as other compliance leads of financial institutions operating in Nigeria, must make sure the companies where they work are not involved in any cryptocurrency transaction, as the regulator in the country has banned such transactions and requires that financial institutions close accounts that engage in them. Failure to comply results in a steep fine, charged per each account they fail to close.

 So how do they make sure the institution is compliant and protected from financial losses? Here are 6 helpful steps Ada shared with us:

1. Make sure to add relevant keywords to your automated transaction monitoring tool. Examples include Crypto, Block chain, Bitcoin, Ethereum, Dog coin, Lite coin etc. 
2. Keep an eye out for new and emerging words, as well as words that may be used by individuals or entities to avoid being caught.
3. Look out for individuals/entities that are sanctioned globally for cryptocurrencies and embed them into your monitoring software. Then, review your customer database and take action if you spot a relationship.
4. When in doubt, discuss the nature of the customers’ lines of business with their account managers.
5. Be mindful of customers who had accounts closed and end up requesting new accounts based on new financial service licences. 
6. Collaborate! You’re not alone in this fight. Compliance officers working in other banks, FIU and Central Bank are usually happy to discuss and share intelligence.

 Tackling the increase in online fraud 

It’s fair to say that, with the world going more and more digital, online fraud is here to stay - and is increasing significantly. A multitude of factors bring in the perfect storm, with customers being targeted when they engage in online payments or via social media scams, and criminals taking advantage of the anonymity of crypto transactions and the increase in vulnerable people at the back of COVID and the ongoing war, for example. 

 Falling victim to fraud doesn’t only impact people’s finances, it can also bring emotional stress and it’s difficult to shake off the feeling that someone took advantage of you. So, what can financial institutions do to be at the forefront of the fight against fraud and protect their customers and communities from this threat? 

 Our compliance superstar, Tommaso Scarpa, shared learnings, based on his experience in the front line. Here are 4 areas he believes financial institutions should focus on:

1. Data – fraud tends to be high volume/low value. Fraudsters will try to spread their tactic as wide as they can to catch as many people as they can. The modus operandi, amounts and account profiles are the same so that means good, timely data can provide excellent insights into the trends and patterns of fraudsters to avoid falling victim to their tactics. 
2. Speed – the money doesn’t hang around. Fraudsters will move the funds they put their hands into very quickly. Slick, efficient processes are required to stand any chance of freezing fraudulent accounts and returning funds to victims.
3. Collaboration – multiple financial institutions, often in different countries may be targeted in a fraudulent payment chain. Collaborating and communicating effectively with them and law enforcement is crucial to positive outcomes. The industry has only to gain when its players stand together against the common enemy.
4. Empathy – the very big difference between fraud and money laundering is the proximity that fraud has to its victims. It can be devastating for them, resulting in significant financial losses but also emotional distress and shame, the reason why many people don’t report a fraud scam straight-away. Recognising this and training your team to deal with the situation is crucial to a true customer-first approach. 

Setting up a compliance function at the speed of business

 Our last guest, Dana Lawrence, was tasked with establishing a quality compliance and internal control function at a rapidly scaling fintech, in preparation for the mass launch of their product. She raised up to the challenge and set it up in record time. 

 Here are the 5 tips she learned along this journey and shared with us:

1. Clearly identify the Big Hairy Audacious Goal (BHAG): in Dana’s case, their startup’s growth was skyrocketing, and they needed to make sure their compliance management system stood up to the test. Otherwise, they’d have to start turning down customers. 
2. Assemble the right team and empower them: the right people had a combination of technical compliance skills and the ability to thrive in an ambiguous and complex environment, typical of a startup that doesn’t have a long track record of well-documented policies and procedures. “These people would help build the rocket as it was flying through space”, she added. This can be exciting to some, but daunting to many. She chose to look for people who had consulting or internal audit experience and were used to being uncomfortable a lot, as building something like this from scratch can be very challenging. Once she found them, she felt she needed to empower and support them to achieve their goal. Once they established a plan together, she stepped out of the way and became a trusted advisor, unblocking problems and providing necessary support. 
3. Stay laser focused: it is very difficult to keep focus when there are so many fires to put out, so it is important for the entire organization to rally behind the project. In Dana’s case, she had the support of the entire organization, and they were all collectively focused on the target at hand. This was crucial to success. 
4. Visualise the positive outcome: this works, not only for professional athletes but for all of us. When roadblocks come up, try to focus on what you’re trying to achieve, and don’t be consumed by the fire you’re fighting to get there. Keep the motivation for yourself and your team going. Don’t look for perfection, there will be future iterations that will give you the chance to fix minor issues.
5. Celebrate success: compliance officers are literally bombarded with issues, such as new sanctions and regulatory fines. Take a moment to reflect and acknowledge your accomplishments. When Dana’s team finally got approval from the board, after a strenuous presentation, the team went out to dinner, celebrated, and shared the victory within the company. 

 If you’re feeling motivated by these success stories, you should consider registering right now for our upcoming webinar on 10th November that will bring you 5 Tips to Supercharge Your Compliance Programs in 2023.