The Practical Guide to Proficiency for the Compliance World
February 23rd, 2017
It was Malcolm Gladwell who first said that in order to master any field, you need 10,000 hours of practice. If we translate that to the working world, that equates to just about 5 years. Unfortunately, as risk and compliance professionals, we don’t have the luxury of time when it comes to mastering alert and case investigations. In fact, we need to become proficient in less than a tenth of that time – alerts will keep building up because suspicious activity, fraudsters, terrorists, money launderers, and other criminals won’t just wait around in one place long enough for us to catch them. So then, how can we accelerate the learning process to get ahead of the game and minimize the time to mastery?
In my view, the solution to accelerated learning involves two parallel tracks. While one track is busy fostering continuous improvement and learning, the other is helping analysts increase their investigations speed. Done right – and done together – organizations can realize the added benefits of increasing investigation speed and accuracy, thereby lowering costs and overall risk. But how can this be done on a practical level?
Let’s tackle accuracy through continuous improvement first. In order to do this, teams should work to build a closed-loop feedback process into investigations. This means that at any point in an investigation, quality teams should be able to validate quality across a variety of fields, including process and policy adherence, decision making, evidence gathering, note taking, and more. Furthermore, sampling investigations should be based on business logic – not just random sampling – ensuring that additional help is directed to the compliance analysts who need it most. And most importantly, whatever feedback they ultimately secure should be sent back to compliance analysts in real time and then communicated back to the quality team with questions and comments.
The next part of the proficiency equation is speed. In this case, managers need to begin by gaining visibility into issues like process bottlenecks, aging, alert inventory, and investigation throughput across all levels of the organization. Then, organizations need to make sure that visibility is actionable – meaning that managers can tune and tweak workflows that aren’t working well, and provide training or extra assistance to analysts whose throughput is declining. Finally, organizations should leverage analytics on aspects within their investigations that require alerts when things go wrong, as well as help analysts learn what works and what doesn’t, while providing guidance based on these learnings.
Mastery takes time – that’s for sure – but let’s make sure our analysts have the tools they need to get there as quickly as possible. We just can’t afford to wait.