AML Leadership
In this week’s newsletter, a conversation with Torsten Kleine Buening, Chief Risk Officer and Compliance Advisor to the CEO, ABA Bank Cambodia, based in Phnom Penh.
Can you give us a brief overview of your professional journey in the world of Compliance and Risk Management?
My Compliance and Risk career started in the US, at the turn of the century, as summer associate for Arthur D. Little, when selecting a data centre for an upcoming start-up. Learning bottom-up the need to balance between being tightly regulated and ensuring agility. This was an experience which shaped my understanding for compliance and risk, and the need to balance.
I held various positions in risk and compliance across Europe, Middle East, South-East Asia and North-Asia. Starting with operational risk and growing more and more into Enterprise-Wide Risk Management & Governance and Compliance, I have worked for local, regional and international organisations, covering conventional and Islamic finance.
What would you say are the top 3 issues of concern for Money Laundering Reporting Officers (MRLO) in banks in Cambodia currently and how are these being managed?
I would think that the top 3 issues for MRLOs in Cambodia are not that different than in other countries. In my view, the biggest challenge is data quality, especially if an organisation was to deploy automated detection systems and reporting. This would be closely followed by the criminal energy of malicious actors, which must never be underestimated – as the recent cases, e.g. from Australia, demonstrate. And finally, to keep up with the constant flow of new sanctions and regulations. As MRLO, you need to have a good team with you that can cover all these bases, and one must be willing to constantly learn and keep challenging.
You have worked in the area of Compliance and Risk in various countries and organisations. What factors, in your opinion, contribute to the varying effectiveness of one organization’s AML compliance program as compared to another organisation?
The key success factor is the Tone from the Top combined with the trust of business that risk and compliance are not set to hinder business, but to ensure prudent and compliant business conduct.?
An organization where risk and compliance is seen as the opponent and only involved last minute or where absolutely not avoidable, will inevitably see many negative confrontations. An early involvement of risk and compliance can turn its considerations into constructive advice rather than business adverse restrictions. Success comes once this vicious circle has been broken.
What is your advice to Compliance Officers as regards the practical skills and capabilities they should develop to become successful in their careers and adding more value to the organization?
Wherever I went – across the different cultures and business models, the key to success was to ensure prudent balancing between business interests and needs, and risk and compliance considerations. Only that way you can convince business to not only follow the rules and adhere to regulations, but also openly discuss with risk and compliance.
Therefore, compliance officers need to sharpen their antennae for business interests and needs, while maintaining an arms length distance when reviewing and challenging business practices, processes and product offerings. And more than ever, compliance officers need to be diplomatic in their tone, while being firm in their approach.
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