Chief Compliance Officer, UniCredit
This is a pre-event interview in the run-up to the Leaders in Finance Compliance Event on 19 September 2024
Maarten: Hi Angelique, thanks for taking the time to speak to us in the run-up to the Leaders in Finance Compliance event on the 19th of September. First of all, could you please introduce yourself?
Angelique: Yes, of course. I’m a chartered accountant by origin. I started my career as an external accountant at a Big4 and then continued as an internal operational auditor within the banking sector. Since 2006, I’m working in the area of compliance, as a consultant and as Chief Compliance Officer. I am now working for HypoVereinsbank, part of Unicredit. During the week, I am living in Munich and in the weekends I’m with my family in the Netherlands, in Laren. I have two kids studying in Rotterdam and I have a lovely husband who is supporting me in this. This way of working and commuting is of course demanding, but I really like the role.
Maarten: Wonderful. What do you like so much and what is so interesting about your current role? And what gives you the energy to do this demanding job?
Angelique: What I like most about my current role at UniCredit, a pan-European Commercial bank, is that it’s a completely different organization than the ones I worked before, also with a different culture. Being a Dutch lady working for a German bank with an Italian parent is of course not always that easy. As I love working in different cultures, you can imagine that this role gives me sufficient challenges. That makes the job interesting. Also, UniCredit has huge ambitions, and we are moving fast. It requires execution power and it requires the right corporate culture. The other part of the job that is so interesting is the role itself. Banks are gatekeepers, ensuring we have a reliable and ethical financial system, keeping criminals out. Therefore, much attention is given to operational resilience, the fight against financial crime and customer protection. These are all very important topics nowadays, with all the challenges from the external world.
Maarten: What do you see as the biggest challenges currently facing the compliance role in financial services?
Angelique: The biggest challenge is, as we all know, the geopolitical environment. It’s of course terrible what’s happening. As said, financial institutions are the gatekeepers for a reliable financial system. And regulators are there to supervise that, overseeing that what we are doing is the right thing. The current external environment does not make it easier. All sanctions against Russia, leading to higher sanctions circumvention risks and very detailed reporting requirements.
Also, all processes around understanding your clients and your client’s business. Monitoring all transactions and reporting suspicious or unusual transactions. A topic that keeps financial institutions busy for a long time and it is not becoming easier. Expectations are getting higher, requiring more sophisticated analyses. The regulatory framework is even getting stronger and still more regulations to come. Also, regulators are having difficulties to manage all of that. For example, the data protection regulation versus the financial crime regulation. They do not always go hand in hand.
Another topic to mention is more concern about consumer impact. I do observe that regulators are taken a broader, more pro-active view of product, pricing and the overall impact of the environment on the consumer. And this is good, as we must protect our customers.
And a final topic I like to mention is the many fraud schemes that do have an impact on the bank’s transactions and payments processes, resulting in losses for both the banks and their clients. Fraud is a relevant topic for the compliance function, often as a joint effort with the security and operations functions. So, compliance is monitoring different kinds of financial, legal and reputational risks from a geopolitical perspective, a customer perspective and from an IT perspective.
Maarten: How do you manage all that? How do you keep track of all those things happening?
Angelique: First, ensuring you have the right team, that you have the right skills and expertise, and the right setup within the organization. It is of course obvious that it is not only about the compliance function but also the business that must keep track of all those things happening. The signals that business gets while managing their risks, together with these in the second line functions, all that needs to work together, within the 3 Lines of Responsibility. I am a strong believer of this model, supported by the right culture and behavior.
Maarten: Interesting. Could you perhaps share some examples or trends that happened in the compliance space the last year that have particularly concerned you or caught your attention?
Angelique: I have to refer back a bit to what I said before. Regulations are not decreasing. Just to mention ESG, DORA and the AI regulations. Don’t get me wrong, they are important and it’s not always easy to adhere to all of them. So, managing all and keep focusing on supporting business and our clients in a timely manner, ensuring a solid financial system, that’s where it is all about.
A trend that has particularly concerned me is the many new reporting requirements, with often very short implementation timelines. For example, the extensive reporting obligations related to the Russian sanctions, including the fast changes from the different sanctions packages. To manage all this, data quality must be high, being able to process and analyze quickly. It goes without saying, these obligations are not only for banks, but for all companies.
Maarten: As you mentioned reporting on data, do you generally speaking see technology as a compliance opportunity or a risk?
Angelique: Tech is creating new types of threats and offers new tools in the fight against financial crime. We know the challenges around AI and black boxes. There is a risk that internal workings and decision-making processes are not transparent, that activities might not have a proper audit trail. Data lineage is therefore key. However, developments are going so fast. Without further investing in AI, it’s difficult to keep up to speed. Coming back to your question, I see it as an opportunity or maybe not even only as an opportunity, but as a must, considering the need to pro-actively manage all compliance risks.
Maarten: What does that mean for the compliance officer and other people working in compliance departments with regard to their knowledge of tech?
Angelique: Within the compliance function, we have the compliance professionals, the craftsmen. But it is much more than only understanding the different compliance themes. Our skills and expertise go beyond these; we have diverse teams, including different backgrounds, also focusing on behavior and root causes. In addition, we of course have IT experts and data analysts. We work together with our colleagues in digital, with model validators in risk. So, the more knowledge of tech, the better we can jointly work together on all requirements around data lineage, data processing and analyses.
Maarten: For people starting in the field of compliance, do you have any tips for them? What should they keep in mind?
Angelique: Well, you ask this to a chief compliance officer who is passionate about her job, it might not be very objective.
So, to all people starting in the field of compliance, you can make a difference. If you like to be a sparring partner for the business, and at the same time you like to challenge, dare to stand up and be courageous as sometimes the business might not like the push back from the compliance officer, then you are at the right place. Working within a compliance department gives you the opportunity to get insight in many areas and processes within your organization. You learn a lot. I often say that compliance is a stepping stone for each person that wants to further grow within a financial institution. Getting experience within a second line function will broaden your profile and risk mindset.
And as said, compliance is not only crucial for banks; it is also relevant for corporates outside the financial sector. So if you enjoy supporting the business and helping it become more sustainable—though we haven’t even touched on ESG, which is also a key topic for compliance—this is an area where you can make a significant impact.
Maarten: We’ll save that one for the event…
Angelique: Yes, definitively. To end that thought, I think that the compliance environment does really give you so much insight and opportunities to grow as a professional. But the most important, you need to stay close to yourself. So my last comment would be to stay close to yourself, stand up, dare to give your view and be courageous. These qualities are essential for effectively helping the business and ensuring that we provide the best possible support to our clients, stakeholders, and community.
Maarten: What a wonderful ending. Well, thanks again for taking the time to speak to us in a run-up to the Leaders in Finance Compliance Event on the 19th of September. Looking forward to seeing you there and to hearing you participate on the Chief Compliance Officers panel discussion.
Angelique: Thank you as well. Looking very much forward to it.
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