A Former BSA Officer’s Advice on Serving Multiple Constituents

*originally published on LinkedIn February 12, 2019

It took a lot of time for me to realize the true dynamic of the position or ultimate role of a BSA Officer (Chief AML Officer or Head of AML). In all honesty it took me leaving the industry and the role to truly understand where I served my constituents well and where I fell short.

In this article I am simply sharing the constituent landscape and a few notes that may help current BSA Officers succeed.

Shareholders

Your obligation as a manager (whether senior or executive level) is to contribute to maximizing shareholder value. As an employee (or shareholder) yourself, you have a direct vested interest in the success or financial health of the company.

Understand the strategic plan and see the big picture.

Board of Directors

The Board can be your best friend. It can also be your worst enemy if you do not ensure that you create a real relationship and engagement. Providing 10 minutes of “annual directors training” falls way short of engagement and certainly does not constitute a relationship.

A real relationship is an actual dotted line to an outside director — someone that you meet with more frequently than annually.

CEO

Whether you report directly to the CEO or not, that person should be directly listening to your counsel/advice on all matters concerning AML.

No offense to other skilled c-suite executives (CRO, CCO, CLO, etc.) but the business of AML is best left to those running the program.

Oversight Committees

Delivering “reports” to ERMCs or other “risk” committees typically results in no action. Oversight is about two specific A’s: Accountability and Action. You should be in a position to drive both — you may also be held accountable and provide reports, but your primary purpose is to drive action across the enterprise specific to AML activities.

Many think cultures start with the CEO — I would argue that it starts in these committees (inclusive of the CEO and senior executives).

Regulators

Ever been on the sidelines for an entrance or exit? Find out about a conversation between “management” and your regulators the day after? If this is the case, you are behind where you need to be. Your job is to be front and center when it comes to “managing” the relationship with the regulators.

Keep in mind other regulatory business may lead to conversations about AML without your presence. The key is to ensure that those colleagues loop you in immediately. More ideally the regulator recognizes that “hey the BSA Officer needs to be involved in this conversation”.

Auditors

The standard view on audit still seems contentious. The Chief Audit Executive should be a key/true partner to you. Audit (whether internal/external/hybrid) should always be uniquely positioned to validate that the AML program is being executed as designed. Where the program is not being executed as designed — Audit is the last line of defense to identify and correct that course.

Be careful of the third party that interprets independence as enforcer — they are not a supervisory body and should not treat you (as their client) as such.

Staff

It’s far too common for staff (whether associate, analyst, line manager level) to have little to no access to the BSA Officer. Unfortunately, this holds true not just at mega organizations, but shops with a dozen or less staff.

Lead strategically (you shouldn’t be involved in every investigation or EDD review) but lead with presence. Presence will inspire and motivate staff. Presence will facilitate communication. Communication will lend itself to an aligned organization/team. An aligned organization/team will ultimately achieve mission success (together).

Vendors

Oddly enough, solutions providers are critical elements/partners of your program. The most honest and the most practical BSA Officers know that they cannot handle every single aspect of a well-functioning program in house. The most intelligent and respected leaders leverage consultants and advisors. And of course, everyone must leverage solution providers — whether it be data, software, or other necessary tools.

Again, relationships are super important here. Vendors can be your best friend or that friend that avoids you.

If you are a BSA Officer struggling with navigating an enterprise — connect with me — happy to help beyond this article!