Reflections of a Compliance Officer

Reflections of a Compliance Officer

There was no such thing as a compliance officer when I was taking up my bachelor's degree.

(And that statement, my friend, has dated me. “Admission against interest,” to quote my professors in law school.)

But then again, compliance is more of an art than a science, as I would say. It is not something that they can just teach you in school. You do not study to become a compliance officer, as it becomes you.

This year, my time in compliance will surpass my years in the “practice of law” following the strict definition and not the liberal interpretation taken in the case of Monsod v. Cayetano (G.R. No. 100113, September 3, 1991).[1]

I was also recently included in Asia’s Top 15 Top Chief Compliance Officers and celebrated a birthday. Compliance Officer Day – which is September 26 – is also fast approaching. All these things are making me pause and forcing me to take stock.

Status of that: In Progress.

While I try to complete this career self-reflection, allow me to share the three things that have kept me going in my “practice of compliance.”

Never Stop Learning

Compliance is never static. It is always in flux.

Therefore, compliance officers are students forever. They are expected to know new regulations and laws. One way to do this is to regularly check the websites of the regulators for new issuances.

One nerd habit that I do if I have the time is to review and reread important old laws and regulations. Sometimes, I would see questions I scribbled on my hard copy of these issuances and would realize that I already know the answers to those questions, or not (no pressure!).

I know a nerdier Compliance Officer whom we call Mr. MORB (i.e., Manual of Regulations of Banks) because he can cite the circular numbers and provisions, shamelessly if I may say, during discussions.

Compliance officers are also expected to be in-the-know. They should always be aware of brewing trends related to their industry, business models and even fraud typologies.

Thus, it is imperative that they attend learning activities. They can maximize free online training that are now readily available or listen to podcasts on compliance (which for me is the best way to pass traffic or long flights).

Have your village

A practicing compliance officer would soon realize that there are just things that are not written in circulars or regulations. This is where your village would be important. Or your army, as they say in K-Pop.

Compliance officers cannot survive on their own. I certainly did and would not. In compliance, there is a strength in number.

I need my village to bounce ideas, or when I simply need to breakdown and cry, figuratively and literally.

I count myself lucky for having mentors, peers, and colleagues in this profession. People I look up to and would call when I need guidance. People who generously share their time and knowledge with compliance-newbies and confused compliance-oldies. Some have become close friends of mine. (Note: You know who YOU are, and I want to thank you from the bottom of my heart).

Your village does not have to be limited to the compliance community. It should be broad enough to include all other disciplines such as business, audit, legal or risk.

And you can give back

Being a compliance officer at the end (or beginning) of the day is still a job. It is what pays the bills and supports the life that you lead.

However, compliance officers have The Job that can directly impact the lives of people.

They can prevent scammers from defrauding people, or children or the elderly from being exploited. They can promote financial inclusion by giving advice on how certain products/services should be designed. They can advocate for an ethical way of doing business. In their own way, contribute to the growth of their respective industries, or even the country.

Most of the time, these nonmonetary returns are not immediately palpable. Nonetheless, one thing is certain: compliance officers can create a ripple, and as they say, sometimes the smallest ripple can affect the entire pond or even cause wave.?

“Love” your work

Allow me to add a fourth thing that has kept me going as a compliance officer which I think is universally applicable to all professions.

As said by Steve Jobs, “Your work is going to fill a large part of your life, and the only way to be truly satisfied is to do what you believe is great work. And the only way to do great work is to love what you do.”

For me, this is does not mean that you must be in love with your work all the time.

Honestly, love would be the last thing on your mind when you are working at 3:00 in the morning trying to beat a deadline.

Loving your work only means when you weigh the challenges and frustration against the triumphs and the joy, the scale will tip towards the latter.

Work like real love takes work. At the end of it, what is important is the work can still ignite your passion, give you purpose, and provide joy. ?


[1] In that case, the Philippine Supreme Court stated that lawyers are considered practicing attorneys if they use their legal knowledge in the active practice of profession. The dissenting opinions espoused the stricter definition stating that the “practice of law” require customarily or habitually holding oneself out to the public, as a lawyer and demanding payment for such service. It is not enough that the person incidentally applies their legal knowledge.


Good reading Atty! Thank you.

回复
Vicente O.

Director, Head of Compliance at DBP-Daiwa Capital Markets Philippines, Inc.

5 个月

Thank you! Compliance Officers must read this.

Javi de Gorostiza

Product Management | Certified PSPO and PSM

5 个月

Well said Guada ?? I appreciate you for being patient in explaining everything to nonCompliance folks like me

Rafael Francisco amparo

Countryside development through rural banking and agricultural finance; financial inclusion, regulatory compliance; Consultant for banks, finance companies, EMIs, OPS, VASP, pawnshops , MSBs and NSSLAs.

5 个月

BSP actually adopted the concept of a compliance function from Citibank-Manila in the mid 1990s.

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