December 22, 2017

The issue of OFAC/sanctions compliance cuts to the root of concerns among compliance officers at corporations and financial institutions doing business internationally.

The increasingly complex nature of sanctions programs has led to the need for qualified persons equipped with the knowledge to tackle the day-to-day compliance and operational duties brought on by the ever-changing rules that govern sanctions policy.

In order to gauge a real-life perspective of those in the business, SanctionsAlert.com has taken the time to ask sanctions professionals what they think is the best way of breaking into the sanctions field and how they see the future of the sanctions industry unfolding.

For this Member Profile, SanctionsAlert.com sat down with Ms. Debra Geister – Managing Director of AML Advisory Services at global consulting firm Matrix International Financial Services (IFS) and SanctionsAlert.com Advisory Board member – to discover her expert opinion about the various ways of breaking into the sanctions industry.

Sanctions Alert:Could you please tell us a little about your background in sanctions and compliance?

Ms. Geister: I started in the industry back in 2001, right after 9/11. At that time, I was working for Bankers Systems, which is part of Wolters Kluwer, where my role was to identify opportunities for solving legal regulatory problems. This threw me into the world of AML (anti-money laundering) and I was tasked with making sure that there were solutions in place for the USA PATRIOT ACT. From there, I went to Lexis Nexis where I spent 10 years driving products, such as Bridger Insight and other data driven products. As such, I have the rare experience of being in charge of the technologies that drive sanctions compliance as well as familiar with the banking/legal issues that can arise. From there, I went back into the banking world to work as a BSA (Bank Secrecy Act) Officer for Meta Payment Systems, one of the largest prepaid issuers in the country, who were having a fair amount of high level AML issues. I was able to completely rebuild their compliance infrastructure from the ground up.

Sanctions Alert: It seems that you entered the sanctions field through AML. Do you think that is typical, or do you think it is possible for someone to go straight into sanctions?

Ms. Geister: Sanctions is a specialized piece of AML and if you look at the reporting structure, sanctions are typically part of the AML unit. It largely depends on the institution. Some are big enough to be able to look at sanctions exclusively, and if so, you could enter the field in that way. From a background perspective, however, it is not a bad idea to have the AML support to be able to understand the sanctions process and where it fits.

SanctionsAlert: What skills do you think are necessary to enter the sanctions field?

Ms. Geister: Understanding the requirements, intentions and objectives of sanctions, and especially how that transcends into the day-to-day issues, is key. I think the most important skill is investigations and analysis. Understanding how to get under the covers and identify if someone is ‘high risk’, being inquisitive, and also flexible in your ideas is paramount in succeeding in the industry. If you can see the bigger picture, it can be very advantageous.

Sanctions Alert: What does a typical day look like for you?

Ms. Geister:(laughs) Honestly, you have to be slightly schizophrenic to keep up as I am constantly jumping from project to project, scenario to scenario. The day can start with having to analyze the potential issues that come from a bank based in the Middle East and then in the same day quickly jumping to a bank in California, which can have a completely different set of issues. In the end, everything is focused on what is best for the client and you must make sure that everything is appropriate for their particular jurisdiction. It is a lot of ‘keeping up’ and switching gears sometimes. But again, the focus is on helping my client.

Sanctions Alert: It seems, from your experience, that you entered the sanctions field through an operational background, rather than a banking or legal background. Can you tell us a bit about how this happened?  Do you think a legal or banking background is necessary to enter the field?

Ms. Geister: I walked into the role with Wolters Kluwer because it sounded interesting. They had actually pursued me because I had spent a lot of time – almost 10 years – consulting for several Government agencies. This diverse experience gave me the ability to adapt and solve problems, which is what they were looking for at the time. You are right that my background is very operational, I am a bit of a data/tech geek, but this has served me well as it has given me the ability to look at things from a very different lens. So, I think it really depends what type of role you would like to pursue in sanctions. However, regardless of the role, the operational perspective is never a bad one to have because it allows you to understand how policy translates into procedure. I think having a legal background is great, but knowledge is necessary in all of the following three disciplines:  governance, operations, and IT. You need all three in order to build a solid compliance program. Additionally, creating policy is much more effective when you understand the operational limitations, restrictions and challenges.

Sanctions Alert: So, in your opinion, it is not necessarily a requirement to have a legal or banking background in order to break into sanctions?

Ms. Geister: No, certainly not. I believe that whatever unique skills we have can be used to contribute to any process. Different perspectives and points of view are very powerful.

Sanctions Alert: Where do you see the sanctions field heading in 2018 and beyond?

Ms. Geister: It’s certainly not going away, as it is a means for firms to be able to manage risk. From a sanctions technology perspective, however, there are some much-needed advancements.At the moment, we are just ‘string matching’. What I am hoping is that we take a bit of a more well-rounded, risk-based approach to sanctions and are able to look at it from a much more holistic perspective. I think this would help manage the fundamental issues we have in sanctions, which is a large amount of false positives. We spend a lot of time on checking these false positives and I am interested to see if we cannot make this method more effective by identifying certain high-risk scenarios. You might call this a more ‘predictive’ approach. In addition, I think that sanctions lists are challenging. We need to look beyond the list and really look at risk. I believe that we need to be better versed in RISK. Understand naming standards in different countries. I have seen situations where an identity was not on a watch list, but based on the country of origin, the name was atypical for the area. Based on this knowledge, we were able to uncover a very high-risk situation. I believe we all need to be more aware of cultural norms in order to identify this risk. This skill will take us much further in our processes and risk management skills.

Sanctions Alert: And what would a ‘predictive’ approach look like?

Ms. Geister: There are a number of systems that take this approach currently. By looking at a number of factors, they are able to screen out the ‘noise’, and identify matches that really need review, which ends up being a fraction of the amount of hits we usually get. This enables us to dive deeper because we have a better quality of match. In addition, a review of “high risk” as opposed to just a character for character match would be a lot more effective in mitigating that risk. We definitely need to evolve our thinking from sanctions as “just” a list matching exercise and treat it more as a risk review.

Sanctions Alert: Just to sum up, what last advice would you give to someone looking to pursue a career in sanctions?

Ms. Geister: Apart from understanding the legal and regulatory side that drives sanctions, you must be sure you understand the operational side of sanctions.  Understanding international affairs and cultural norms are additional tools you can obtain that would make you extremely valuable to an organization. You don’t necessarily need a legal mind or background to be able to do this job. I think there is just as much value in having an operational expertise and skills and being able to creatively solve problems. That is what we do after all – we solve problems.

*Ms. Geister has spent 15 years in a leadership role in banking compliance and in a vendor capacity. She launched Navigator Consulting Group, LLC. to help companies focus on identifying improved processes surrounding analysis and detection of risk and opportunities. Her team identifies and implements effective detection process and systems and other opportunities for effective, improved business process through convergence, improved investigation practices, typology management and similar areas. In addition, the teams Ms. Geister employs leverage her success in consumer-focused product building and management by helping companies build effective products for the Financial Services sector. Ms. Geister spent three years as Senior Vice President, leading the combined Fraud and Bank Secrecy Act Unit at a Financial Institution. She also spent 15 years in Consulting, Operations and Product Management for Wolters-Kluwer Financial Services and LexisNexis Risk Solutions.

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