Moderator
This is a pre-event interview in the run-up to the Leaders in Finance Compliance Event on 19 September 2024
Maarten: Michelle Fisser, thanks for taking the time to speak to Leaders in Finance in the run-up to the Leaders in Finance Compliance event on September 19th. To start off, could you please introduce yourself?
Michelle: Thanks Maarten. I have been a compliance officer since 2003, a time when the field of compliance was relatively unknown and, even if recognized, not particularly popular. However, I did not really mind, because I believed I could make an impact in this role, not only in making things better, but also in preventing issues from happening. Throughout my career, I have held compliance roles in different types of organizations, both within and outside the financial sector. Up until 2016, I served as a compliance officer in the financial industry, with the last eight years in a global capacity. Following that, I joined EY, where I spent six years as a compliance consultant, working with many types of organizations. During this time, I have learned about the use of technology and how it can enhance the effectiveness and efficiency of the compliance profession. In 2021, driven by a desire to pursue several projects that had long been on my agenda. One of these was writing a practical compliance manual, but this goal evolved into developing practical compliance training programs on my platform, Compliance in Motion. Besides this, I am an advisor, trainer and speaker in my day-to-day work.
Maarten: Thanks. It is probably hard to summarize, but if you would try, what do you like so much and what is so interesting about your current role?
Michelle: When I was a compliance officer, I believed that there was no nicer or more challenging role, being the ‘spider in the web’, building systems to prevent risks and learning not just from regulatory requirements but also from the specific products, instruments, and environments I worked in. I also loved working with people since compliance management is very people centric. As a consultant, I realized I could step back and view things from a broader perspective. While I still dive into the details and offer advice, I can also draw on my experiences across various roles and engagements, which allows me to see the bigger picture and connect the dots in ways that might not be possible when you are in a single organization.
Maarten: What is the most challenging aspect of being a compliance professional?
Michelle: Being a compliance officer in 2003 was being a pioneer. There were hardly any compliance officers, so I had little guidance on where to begin. For the first decade, it was often just me, or a small team, navigating everything on our own, especially in smaller firms where I was often the sole compliance officer. We had to make decisions without established processes or much external support. While international influences from the US, UK, and later the EU started to shape the field, the practical “how-to” of compliance—preventing issues or handling incidents—remained challenging. Being the only compliance professional in an office was particularly tough because there was no one to discuss these challenges with. Today, there are many more compliance professionals, especially in larger organizations. However, what I notice now is the fragmentation of roles. You have specialists focused on specific areas like sanctions, money laundering, or corruption. But also related to privacy, ESG and even AI Compliance. Yet, all these topics are interconnected, and it can be challenging to integrate them effectively. Also, modern financial crimes, no matter which region, have become increasingly sophisticated. Take for instance ‘pig butchering’ in the Asian region where IT professionals are offered good jobs. They happen to end up with the task of scamming people and committing fraud and cybercrime on a global scale. Due to the complexity of these crimes, blending with corruption in these countries to local officials, it is hard to detect and recognize the crimes. It is, on the other hand, encouraging that those who need to understand these complex financial crimes are beginning to do so. Awareness among the right people allows for more proactive measures. However, there is a need for greater support from governments, both in the Netherlands and at the EU level, to develop better tools and resources for financial institutions, rather than just introducing more regulations that may not always be effective. And miss a lack of relationship.
Maarten: What do you currently see as the biggest challenges with regards to the compliance role in financial services?
Michelle: First of all, I would say one of the biggest challenges is navigating through contradictory regulatory requirements. For example, while they are required to identify money laundering, privacy regulations often hinder effective solutions. This ongoing debate raises the question of what really matters in terms of data use. See also the previous response.
Secondly, the increasing number of regulations is a challenge. In the end, more regulations do not necessarily lead to better prevention of financial crimes. Instead, a risk-based approach is needed, one that is more fluid and requires a deeper understanding.
Another challenge is, in my view, the fact that compliance professionals are not always well equipped due to a lack of standardization, for example risk assessments, policy framework design and Compliance cycle management. Furthermore, compliance became a business model where a lot of money is earned but unfortunately compliance organization did not increase effectiveness and efficiency. This leads to overly complex policies and procedures that are often ineffective because they are too broad and not focused on practical application. Not to mention other negative consequences from a broader perspective.
Maarten: Right. That makes me wonder, what do you think are some of the key characteristics of a great compliance professional?
Michelle: A great compliance professional needs a very diverse skill set, I would describe it as being “a sheep with five legs.” To sum them up: strong communication skills, since you work with a lot of different people; business understanding, you should know who and what you are working with, which also builds trust; curiosity, to identify potential risks and staying ahead of developments; background and knowledge of regulations, and; being able to work in teams and combine knowledge, for example with IT professionals and other specialized teams.
Maarten: It sounds indeed like a diverse role which entails a lot of knowledge which keeps evolving with new regulations. You mentioned the role of technology before. Do you see technology as a compliance opportunity or as a risk?
Michelle: Initially, I would say that technology, including what we now call robotics, can be seen as a big opportunity. It allowed the automation of repetitive processes such as handling sanction alerts, which made the work of the compliance officer easier. These kinds of machine learning become increasingly important and better developed, even to the point where fraud is difficult to recognize, which introduces new risks. To summarize, while technology enhances compliance and efficiency, it also brings challenges and new risks. I consider the new AI Act therefore also as valuable, but it is key to align this with the already existing regulatory landscape.
Maarten: You mentioned in the beginning of this interview that the compliance field is rapidly changing. Do you have tips for starters in the industry?
Michelle: When I started my first compliance role at Fortis Clearing (now ABN AMRO Clearing), I focused on two main things. First, I tried to understand business by taking courses and asking colleagues about their roles, daily operation and potential compliance risks they identify. Second, I completed a basic compliance training. I repeated these two things in every role I performed following this one; diving deeper into the business to understand what the role of compliance should be about in context of the organization.
Also, I would recommend starters to clarify the expectations of your role. Not only from your side, but also what you can expect from others and where to turn for escalation and improvement. Engaging with professional communities, like the Community for Compliance Professionals, can also be helpful. They provide resources and standards, such as the professional code outlining what makes a good compliance professional. Additionally, I would say it is important for starters to understand that compliance has evolved beyond regulations, but it also includes ethics, integrity management and a more risk-based approach.
Maarten: Thank you. As the moderator for the upcoming Leaders in Finance Compliance event, what are your expectations for the event, and what aspects are you most looking forward to?
Michelle: First of all, I am excited about the line-up of speakers at the event, I think there is a lot of excellence on board, and they represent a large part of the financial sector, offering diverse perspectives. It is also valuable that some speakers will include clients from other sectors, providing insight into their experiences and the challenges they face with financial institutions. Besides this, I look forward to meeting people who have the same focus, learning from each other and connecting as one big community.
Maarten: Thanks Michelle Fisser, moderator of the Leaders in Finance Compliance Event on 19th of September, for taking the time to speak with us. We look forward to having you at the event.
Michelle: Thank you!
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