Compliance FC Final - Flipbook - Page 6
㬀甀
0
䰀℀
z
0
愀⸀
㬀甀
昀儀
昀儀
u
�
㰀⠀
m
尀砀
猀琀
N
0
N
w
愀⸀
琀挀
昀관
w
�
�
㰀⠀
㬀甀
昀관
z
w
㬀甀
昀ⴀ
�
u
w
�
w
㬀甀
툀堀
u
尀砀
㰀⠀
z
㰀⠀
z
椀ꌀ
漀愀
w
u
z
㰀⠀
琀甀
愀⸀
㬀甀
0
u
攀쐀 themes in
compliance & financial
crime recruitment.
Senior-level recruitment challenges
Emphasis on cost control
Recruiting 昀漀r senior compliance positions has
become increasingly di昀昀icult. The FCA strongly
prefers that SMF 16 and SMF 17 vacancies are
filled by people who have previous experience
in those roles. This limits the available talent pool
and potentially degrades it, as the market includes
individuals who gained promotion to that level
when the regulator was more 昀漀rgiving and strong
candidates were in sho爀琀 supply.
It has been di昀昀icult 昀漀r financial services businesses
to increase sales and revenue over the last 12+
months, invariably leading to a 昀漀cus on controlling
costs. All compliance teams are now stretched, as
budgets have been cut and replacement hires are
delayed wherever possible.
While the F䌀䄀 can approve appointmen琀猀 without prior
registration to SMF 16 or SMF 17 roles, it is much harder
to do so and there is a clear incentive to recruit 昀爀om the
talent pool of candidates with existing experience.
Heads of Compliance are becoming uncom昀漀爀琀able
with both the level of capability in their function and
the prevailing culture among leadership and the
Board, with seemingly li琀琀le understanding of the role
of compliance as a business enabler and protector.
A similar cost control trend has emerged in financial crime.
Ne爀瘀ousness around business prospe琀혀 has cu爀琀ailed
a挀琀Mties and big proje琀혀 have come to an end. The roles
that are available in瘀漀lve re-hiring 昀漀r positions that either
became vacant or 眀攀re created by amalgamation - few
new positions are hi琀琀ing the mar欀攀t
Financial crime is highly cyclical, however. Invariably,
financial crime recruitment is prioritised a昀琀er a
regulatory intervention or fine. People are recruited,
the problem is addressed, and then, as trading takes
a dip, this resource is released. As a result, financial
crime functions become under-resourced, and the
cycle sta爀琀s again.
Recent comments from senior in-house practitioners
and leaders in the world of financial crime
consultancy indicate that large fines and regulato爀礀
sanctions are on the horizon. We there昀漀re expect a
flow of financial crime-related positions to commence
late in Q3 or early Q4.
Fraud as a driver of demand
Significant investment has been made into measures
that combat retail fraud, and the Economic Crime
and Transparency Bill (ECTB} is 昀漀cusing managers'
a琀琀ention on the level of responsibili琀礀 they hold for
customer decisions.
Credit card companies are well versed in deploying
sophisticated analytics to identi昀礀 suspicious
transactions in real-time, but retail banks have been
slower on the uptake. Many firms are yet to provide
similar levels of prote挀琀ion to their bank account
holders. The ECTB is likely to ensure this dispari琀礀
in customer protection is addressed with enhanced
levels of transaction monitoring and risk profiling,
which is likely to create new oppo爀琀unities in these
areas moving 昀漀rward.