I found that I liked the compliance job very much; it was truly the flip side of my life as a money launderer. Whereas, in my earlier life, I was trying to move the proceeds of crime into the financial system, as a compliance officer my task was to deny the entry of which I believed to be criminal funds, funds whose provenance were suspicious, or funds from entities whose beneficial ownership could not established by the preponderance of the evidence. I used very objective standards in enhanced due diligence investigations, and demanded complete cooperation from new accounts/ customer relationship/sales staff, who received a short list from me of the exact documents and information we needed to approve the high-risk clients. At times, the staff who stood to gain substantially from our approval of their client would seek to influence me, or even take proactive steps to circumvent compliance, but I usually caught them in the act when I verified the information through my own devices. Naturally, once their subterfuge had been exposed, the staff members became quite sheepish, but never apologetic. They wanted those clients accepted by compliance, notwithstanding their dodgy nature. Did they resent me? You bet they did, but they also came to respect me, because I was totally on their side if the client passed muster.

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