Pennell Hart: Women in Compliance

SO: For many people the route into compliance is nonlinear, can you tell us how you entered the profession and what motivated you to pursue this career path??

IT: I started my professional banking career back in 1997 in Internal Audit in Citigroup (Citibank NA back then) and joined the Compliance function as one of the first compliance officers of Citigroup in 2002. Up until 2002, the Banks had more of Internal Control and Internal Audit functions and Compliance was not a function on its own or there were no appointments of a Chief or similar level of Compliance roles. Following the Enron scandal in the US back in 2001, Citigroup was the first bank globally to form Compliance as a function to ensure the thorough identification and management of regulatory risk from an end-to-end perspective. Of course, we cannot forget the 9/11 which also took place in 2001, bringing up the focus light on the funding of terrorism, money laundering which led to the issuance of the US Patriot Act also in 2001.

Moving into Compliance and being one of the first Country Compliance Officers of Citigroup was a career and life defining moment for me. My journey as a compliance executive leader is now into its 22nd year of nonstop dynamism, continuous self-learning which is great fun and helping younger banking professionals to pursue their career in compliance.

Compliance has always kept me busy, on the endless learning and growth path seeing how different world events, banking scandals, economic crisis led to the evolution of countless regulations in many developed countries and worldwide. Trying to keep abreast with all the changes, while continuously having to challenge yourself how to integrate and embed the regulations in an efficient manner coupled with support for business growth, identifying risks, and designing mitigating controls, and more importantly, being an advocate for strong work ethics, sound culture and conduct programs always leading by example are the reasons why I continue to be a proud compliance officer after 22 years and still counting.?

SO: What are some of the common misconceptions about compliance, and how do you work to dispel them?

?IT: For a Compliance Officer, the fight against misconceptions rarely ends or rests. I love fighting against some of these common misconceptions which can be listed as follows:

“Compliance is the roadblock to growth and revenue making”

“Compliance always creates obstacles and challenges”

“We could be doing better if we did not have compliance in place”

“When something goes wrong: Compliance did not do it! Compliance did not provide enough support!”

“Compliance does not understand the business”

And the list can go on.?

Over the years I spent in compliance, my passion and energy never faded when it comes to doing the right thing and ensuring that my team members, stakeholders, internal as well as external customers can understand and start appreciating the value of compliance. The key to success in this regard is to be always open, transparent, tirelessly educating and building empathetic relationships. A compliance officer should always be a good listener, understand the product, service or the business need to be able to adapt tailored solutions to the challenge in hand. Compliance is never a “one size fits all”, “cut the corners” or a “cut/paste” approach. When you invest in the required amount of time, listen to your business’s needs and follow a solution-oriented mindset, there is no reason why the misconceptions cannot be dealt with.

SO: What do you think the future of compliance looks like and how can companies and professionals prepare for upcoming changes??

IT: The future of compliance is exciting, challenging and always ready to surprise. Of course, it has its own nuances when it comes to the geography and the regulatory landscape one is working at. Let’s take UAE for instance.?

As everyone knows, UAE is aiming to be the center of the world for digital evolution, fintech industry, blockchain, AI technologies, metaverse and all of that. So, this is one side of the UAE.?

On the regulatory side, UAE regulators are aggressively aiming to leverage the status of compliance industry by integrating technology as well as continuously issuing new regulations and rules. In the last three years or so, we have seen very good regulatory guidance being issued by the Central Bank of UAE, Securities and Commodities Authority (SCA), Dubai Virtual Assets Regulatory Authority (VARA), Abu Dhabi Global Markets (ADGM) and other authorities.?

However, UAE is still in the FATF grey list, which in very short terms means, has still room for growth and maturity until the market can be considered as safe and sound containing transparent and ethical standards.?

The banking sector in the UAE is still struggling to implement and comply with the basics of the compliance such as having sound conduct and ethical policies and processes in place, be it financial crime, consumer protection, market conduct or securities regulations – the list can go on. “Implementation” vs “Embedding” is the real deal when it comes to assessing the maturity of any compliance program. “Embedding” is often overlooked whereas is the most important part of “what good looks like” - which means to add regulations and ethics into your organizational DNA chain and making your immune system vulnerable proof.

At the heart of everything, lies the importance of embracing good conduct, transparency, integrity and promoting good compliance culture, rather than seeing compliance practices as a tick-box, regulatory obligation or at times a burden.

Companies should start seeing compliance more than a bunch of regulations and an obligation to fulfill and should understand that compliance can help in more than many ways to the sound growth, cost efficiency, risk management, employee wellbeing, better working environment, innovation and the list goes on.

Compliance professionals need to maintain a courageous and strong mindset, continue to increase their knowledge and skills by constantly investing in themselves, and be the advocate for change.

As we keep hearing a lot about ESG (Environmental, Social and Corporate Governance), sustainability, green products, etc in the last couple of years, the majority of ESG, especially Social and Corporate Governance pillars of it are nothing new; being driven out of sound and decades old fundamentals of compliance.

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SO: How do you think the compliance market here in the UAE differs from other parts of the world?

IT: UAE regulatory market is still evolving and trying to catch up with the developed countries from a policy and law-making perspective. Over the last 2-3 years, the UAE regulator has issued numerous good regulations. The issuance of these regulations should continue but more importantly, since the proof of the pudding would be in the eating of it (if I may say so), the supervision, embedding of regulations, enforcement should continue to force the hand of the companies for raising the profile of their compliance functions and status of their compliance programs. In other parts of the world, such as the US, UK and rest of the Europe, compliance has shown a tremendous progress in the last 25 years or so. In this regard, UAE compliance environment in the financial services industry has still room to grow and find its place in the global arena for housing best compliance practices. The aim of the market should be targeted at a higher level to establish international best practices rather than just implementing the bare minimum standards.

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SO: Pennell Hart plan to gather some solid data on this over the next few months so the facts remain to be seen, but do you feel women are well presented at leadership level in compliance in the region? If so, what are some of the key skills and experiences that women bring into the field of compliance, and how do you see diversity impacting the industry??If no, how can this be addressed?

?IT: The answer to the first part of this question is a simple NO. For solid data gathering, have a look at the number of female Chief Compliance Officers, Board and Audit Committee members as well as the female senior compliance officers in the region. Diversity in this regard is one of the greater challenges for the UAE compliance market as well as the GCC region.

Overall banking industry in the UAE is still very much a male dominant market.

Both males and females have different characteristic traits that they can bring into the senior compliance roles. However, females; with their orientation to paying more attention to details, being more empathetic and their ability to work around multi-tasking and competing priorities all at the same time, their courage and sound decision making are some of the reasons why female Chief Compliance Officers or them being in executive compliance leadership roles can help to leverage the quality of the compliance industry.

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SO: What type of company culture is conducive to driving an effective compliance program? ?

IT: Open, transparent, trust based, respectful, well established, where integrity is the main principle, doing the right thing is promoted and poor behaviors are never tolerated, meritocratic with no-fear culture, mindful and energetic.

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SO: Tell me something about yourself that has nothing to do with compliance…

IT: I do love history and psychology, reading biographies, real life events and getting ready to adopt my first dog which will be a maltipoo.