Share these talks and lectures with your colleagues
Invite colleaguesPractice paper
Understanding the human factor in financial crime compliance
Journal of Financial Compliance,
6
(4),
368-384
(2023)
Abstract
Financial crime compliance (FCC) is a complex and multifaceted field that requires a thorough understanding of various risks, including those related to human behaviour. In risk management, it is common to assume that the human factor is a source of risk without fully understanding the root causes or finding solutions that are widely understood. This paper aims to shed light on the concept of human risk in FCC by examining both the compliance perspective and the cognitive psychology of human behaviour. Numerous examples are provided to illustrate different types of risks and categorises them as errors or violations based on various factors such as knowledge and skills. By analysing the psychological factors that contribute to human risk, the paper seeks to provide a more comprehensive understanding of this important issue and suggests ways to mitigate it, focusing on the role of compliance culture, identifying red flags and providing a formula for reducing or eliminating human risk. Given the increasing pressure on financial institutions to comply with complex regulations and prevent financial crime, it is crucial to consider the human factor and its impact on FCC. By understanding the underlying causes of human risk, financial institutions can take steps to mitigate this risk and better protect themselves and their customers.
Keywords: financial crime compliance; risk management; human risk; cognitive psychology; compliance culture; robust compliance programme; feedback culture
The full article is available to subscribers to the journal.
Author's Biography
Gizem Tansu is an international jurist who specialises in international and European law and organisations such as Nato, United Nations and tribunals. She has always had a long-term ambition to use her expertise for the greater good in the public and private sectors. Mrs Tansu's career began at Swift, where she helped financial institutions with legal queries, mergers and acquisitions. When the company decided to expand into financial crime compliance (FCC), specifically in anti-money laundering (AML), sanctions and anti-fraud, she was the first expert with a legal background to join the new team. As the regional head of financial crime compliance initiatives in Central and Eastern Europe, Benelux and Austria, she worked for over eight years with regulators and all types of banks to create awareness in the areas of AML, sanctions and fraud and to adopt best practices. She continued her career at Euroclear as the manager of the Core Regulatory Advisory Team, specialising in the securities market in addition to the payment sector. Over the past decade, she has carried on collaborating with financial institutions and regulators on new regulations and best practices. As a spokesperson, she has continued to create awareness through international AML conferences and has become a sought-after motivational speaker for compliance officers around the world. Recently, she joined the Worldline group as the global AML and sanctions manager. She continues to pursue her goal of bringing compliance officers together and raising awareness not only of FCC risks, but also of ways to improve compliance culture.
