In this series, we interview compliance officers and other financial crime experts to find out the latest career tips, industry insights, and interesting trends you need to know. Sign up for our newsletter so you don’t miss out on upcoming interviews!
In this installment of our Fincrime Fighters Expert Interviews, we had the privilege of speaking with Rebecca Marriott, VP Risk & Compliance and MLRO at Tide. You can find Becky on LinkedIn.
I’m Becky and I’m VP Risk and Compliance and MLRO at Tide, so I oversee our second line of defense team.
I started my career in physical risk management, working for a defense company. I then got my Masters in Countering Organized Crime and Terrorism and did some work on the 2012 London Olympics in intelligence. After that, I went to HSBC to do financial intelligence – I didn’t know anything about financial crime at the time, but my intelligence work in the Olympics lent itself to financial intelligence analysis.
At HSBC, I spent three years on the financial crime side working on some fascinating cases involving global money laundering and sanctions evasion. I worked extensively on terrorist financing, for example looking into ISIS financing when they were asserting themselves as a militant group in the Middle East region and no one could pinpoint how they were sourcing their money, or how the bank might be impacted.
Then, Gemma Rogers, who was my boss at the time, and her husband, who was my boss at the Olympics, both left HSBC to start up Fintrail. I have an enormous amount of professional respect for Gemma and Rob and what they did sounded interesting, so I followed them there. I joined as their first employee working on this thing called fintech – no one really knew what it was, but it was a buzzword that was intriguing and full of possibility. I worked with a diverse array of different companies at Fintrail, including several “cool”’ fintechs, on various projects in the financial crime space. We worked on risk assessments, new products, and particular issues people were facing, and carried out training, attended conferences and engaged with industry. I helped set up the Fintech Fincrime Exchange, and it’s incredibly satisfying to see where it is today.
Tide was one of my clients, so that’s how I ended up here. I was initially focused on the financial crime side, which is when I became MLRO. Then I started asking questions – for example, who’s doing all this regulatory reporting, are we looking at this operational risk, how are we handling customer complaints? Our CEO then made me VP of all Risk and Compliance. I went from taking on one risk classification in financial crime risk to looking at seven risk classifications, which is what we have now four years after I started.
The fact that we make an impact. It sounds like a cliché, but we’re genuinely helping the business scale and supporting new products.
It sounds like a cliché, but we’re genuinely helping the business scale and supporting new products.
We have influence internally to continue to build a best practice, Risk and Compliance division, at a global level. There’s no single thing we work on. We are all over the business. We’re making an impact every day to help our customers and our business.
I get huge satisfaction out of the work that we do, and I am learning every single day. There’s a satisfying variety of things the teams and I work on, and integrating best practice with a company growing at scale is incredibly fulfilling. There is not a single day that I finish thinking, “Oh, I’m not mentally stimulated today.” Every day there is a new topic that you have to dig into and learn about.
The thing that I worry about the most is that I’ve missed something. What we do is business critical and it matters. I’m also director of our entities and this part of my role provides reassurance to the board. I’m SMF 17 and 16, so I’m responsible to the FCA for compliance and money laundering.
We’ve put a lot of structure and formality into place. My concern, as in other parts of the business, is the unknowns. I like to take my time to get my head around an issue, understand the detail, and give meaningful, impactful input. So the key to that - as one person can’t be everywhere in a business - is to be continuously across the latest knowledge in my area, know how and when to delegate, and the bedrock of that is to hire a great team that knows what it’s doing.
Resilience and calm inside and out. If your VP for Risk and Compliance is coming across as stressed, that’s not a good signal to the rest of the business. Being calm, resilient, and having the ability to navigate complexity in and out of the business, as well as providing counsel and insight are crucial to being successful in this role.
Being calm, resilient, and having the ability to navigate complexity in and out of the business, as well as providing counsel and insight are crucial to being successful in this role.
The team consists of a hundred people who look to me to be a kind of north star for the division and industry.
One question I always ask is: what makes you stressed? It’s very important to understand people’s motivations and what they find stressful.
In the financial crime space, there are those individuals who want to leave banks and join a fintech, because they want the pace and the excitement, but living and working at this level of speed is a different matter. It’s a life choice. This question reveals much about people’s motivations for joining Tide. If they find uncertainty, continuous change, and a fast-paced environment stressful, we may not be the right work environment for them.
In terms of financial crime specific questions, for a more junior person, I’d always ask them what they think the biggest financial crime risks are to Tide. Now that I only interview more senior people, I want to understand not so much their basic level of knowledge, but how they would apply their knowledge to Tide or how they would build a particular framework.
Money laundering and fraud. Specifically, the authorized push payment (APP) fraud piece is the one that we’re most focused on at the moment given the consultation that’s currently taking place and the work that’s happening around APP fraud. It’s a huge focus for us and the industry. We’re preparing as much as possible, but we’re really going to have to see what happens from the consultation.
One thing we’re really drilling down on is improving our models with the data science team. Ultimately, the best way we can combat this is with data, sophisticated and intelligent models, machine learning, and systems.
Ultimately, the best way we can combat [fraud] is with data, sophisticated and intelligent models, machine learning, and systems.
There’s a laser focus at Tide on upgrading these even more and we have a huge amount of support from our CEO to do this. We’ve got to get it really right and be able to show we’ve done everything we can.
The other piece on this is customer education. We’re working hard to keep our customers up to date, educated and informed – it’s not a system or tech thing, here it’s the soft skills that deliver the hard messages that people need to be vigilant at all times, and protect their own identities and security.
Cable is one of the ones I’m excited about. Cable will save us a huge amount of time in our second line team, and that’s how we’ve built our business case in terms of efficiencies. It does 100% of testing on something that a person can do 3% of testing on – it’s a no-brainer.
[Cable] does 100% of testing on something that a person can do 3% of testing on – it’s a no-brainer.
From Cable’s proof-of-concept, we found some really interesting points to drill down on. We’re really interested to see the impact it has and how we can use it as a business.
It varies. At the moment, I’m thinking in hard detail about our India business and the financial crime work we’re doing there. A month ago, I’d have said sanctions given the conflict in Ukraine. As a division we have to be agile and responsive to the times.
It’s not so much an individual issue, but more of a theme. We have a very structured way of managing things, which means I don’t worry about the odd topics floating around, and I’m comfortable that it’s all contained. If we find things in the second line, they get assigned, tracked, and escalated. I don’t wake up and think whether our PEP screening is working – I have comfort that we have systems and controls in place to measure that.
SAR automation is a no brainer. It is the most time-consuming job for the analysts, and I find it infinitely frustrating that SARs are not automated.
The existing system is a decades-old legacy system – firms have all the responsibilities and requirements to adhere to, while working with age-old processes. It’s time-consuming work. If I had a magic wand, I’d wish SARs into oblivion.
To learn more about how Cable provides Automated Assurance of your financial crime controls, get in touch with us here.
Compliance as a Competitive Advantage: A Perspective from the Frontlines of Embedded Finance.jpg)
Why Banks and Fintechs Need Good Compliance Programs: Understanding Consent Orders and Their Impact
Will AI + Automated Testing Eliminate the Third Line of Defense?In this series, we interview compliance officers and other financial crime experts to find out the latest career tips, industry insights, and interesting trends you need to know. Sign up for our newsletter so you don’t miss out on upcoming interviews!
In this installment of our Fincrime Fighters Expert Interviews, we had the privilege of speaking with Rebecca Marriott, VP Risk & Compliance and MLRO at Tide. You can find Becky on LinkedIn.
I’m Becky and I’m VP Risk and Compliance and MLRO at Tide, so I oversee our second line of defense team.
I started my career in physical risk management, working for a defense company. I then got my Masters in Countering Organized Crime and Terrorism and did some work on the 2012 London Olympics in intelligence. After that, I went to HSBC to do financial intelligence – I didn’t know anything about financial crime at the time, but my intelligence work in the Olympics lent itself to financial intelligence analysis.
At HSBC, I spent three years on the financial crime side working on some fascinating cases involving global money laundering and sanctions evasion. I worked extensively on terrorist financing, for example looking into ISIS financing when they were asserting themselves as a militant group in the Middle East region and no one could pinpoint how they were sourcing their money, or how the bank might be impacted.
Then, Gemma Rogers, who was my boss at the time, and her husband, who was my boss at the Olympics, both left HSBC to start up Fintrail. I have an enormous amount of professional respect for Gemma and Rob and what they did sounded interesting, so I followed them there. I joined as their first employee working on this thing called fintech – no one really knew what it was, but it was a buzzword that was intriguing and full of possibility. I worked with a diverse array of different companies at Fintrail, including several “cool”’ fintechs, on various projects in the financial crime space. We worked on risk assessments, new products, and particular issues people were facing, and carried out training, attended conferences and engaged with industry. I helped set up the Fintech Fincrime Exchange, and it’s incredibly satisfying to see where it is today.
Tide was one of my clients, so that’s how I ended up here. I was initially focused on the financial crime side, which is when I became MLRO. Then I started asking questions – for example, who’s doing all this regulatory reporting, are we looking at this operational risk, how are we handling customer complaints? Our CEO then made me VP of all Risk and Compliance. I went from taking on one risk classification in financial crime risk to looking at seven risk classifications, which is what we have now four years after I started.
The fact that we make an impact. It sounds like a cliché, but we’re genuinely helping the business scale and supporting new products.
It sounds like a cliché, but we’re genuinely helping the business scale and supporting new products.
We have influence internally to continue to build a best practice, Risk and Compliance division, at a global level. There’s no single thing we work on. We are all over the business. We’re making an impact every day to help our customers and our business.
I get huge satisfaction out of the work that we do, and I am learning every single day. There’s a satisfying variety of things the teams and I work on, and integrating best practice with a company growing at scale is incredibly fulfilling. There is not a single day that I finish thinking, “Oh, I’m not mentally stimulated today.” Every day there is a new topic that you have to dig into and learn about.
The thing that I worry about the most is that I’ve missed something. What we do is business critical and it matters. I’m also director of our entities and this part of my role provides reassurance to the board. I’m SMF 17 and 16, so I’m responsible to the FCA for compliance and money laundering.
We’ve put a lot of structure and formality into place. My concern, as in other parts of the business, is the unknowns. I like to take my time to get my head around an issue, understand the detail, and give meaningful, impactful input. So the key to that - as one person can’t be everywhere in a business - is to be continuously across the latest knowledge in my area, know how and when to delegate, and the bedrock of that is to hire a great team that knows what it’s doing.
Resilience and calm inside and out. If your VP for Risk and Compliance is coming across as stressed, that’s not a good signal to the rest of the business. Being calm, resilient, and having the ability to navigate complexity in and out of the business, as well as providing counsel and insight are crucial to being successful in this role.
Being calm, resilient, and having the ability to navigate complexity in and out of the business, as well as providing counsel and insight are crucial to being successful in this role.
The team consists of a hundred people who look to me to be a kind of north star for the division and industry.
One question I always ask is: what makes you stressed? It’s very important to understand people’s motivations and what they find stressful.
In the financial crime space, there are those individuals who want to leave banks and join a fintech, because they want the pace and the excitement, but living and working at this level of speed is a different matter. It’s a life choice. This question reveals much about people’s motivations for joining Tide. If they find uncertainty, continuous change, and a fast-paced environment stressful, we may not be the right work environment for them.
In terms of financial crime specific questions, for a more junior person, I’d always ask them what they think the biggest financial crime risks are to Tide. Now that I only interview more senior people, I want to understand not so much their basic level of knowledge, but how they would apply their knowledge to Tide or how they would build a particular framework.
Money laundering and fraud. Specifically, the authorized push payment (APP) fraud piece is the one that we’re most focused on at the moment given the consultation that’s currently taking place and the work that’s happening around APP fraud. It’s a huge focus for us and the industry. We’re preparing as much as possible, but we’re really going to have to see what happens from the consultation.
One thing we’re really drilling down on is improving our models with the data science team. Ultimately, the best way we can combat this is with data, sophisticated and intelligent models, machine learning, and systems.
Ultimately, the best way we can combat [fraud] is with data, sophisticated and intelligent models, machine learning, and systems.
There’s a laser focus at Tide on upgrading these even more and we have a huge amount of support from our CEO to do this. We’ve got to get it really right and be able to show we’ve done everything we can.
The other piece on this is customer education. We’re working hard to keep our customers up to date, educated and informed – it’s not a system or tech thing, here it’s the soft skills that deliver the hard messages that people need to be vigilant at all times, and protect their own identities and security.
Cable is one of the ones I’m excited about. Cable will save us a huge amount of time in our second line team, and that’s how we’ve built our business case in terms of efficiencies. It does 100% of testing on something that a person can do 3% of testing on – it’s a no-brainer.
[Cable] does 100% of testing on something that a person can do 3% of testing on – it’s a no-brainer.
From Cable’s proof-of-concept, we found some really interesting points to drill down on. We’re really interested to see the impact it has and how we can use it as a business.
It varies. At the moment, I’m thinking in hard detail about our India business and the financial crime work we’re doing there. A month ago, I’d have said sanctions given the conflict in Ukraine. As a division we have to be agile and responsive to the times.
It’s not so much an individual issue, but more of a theme. We have a very structured way of managing things, which means I don’t worry about the odd topics floating around, and I’m comfortable that it’s all contained. If we find things in the second line, they get assigned, tracked, and escalated. I don’t wake up and think whether our PEP screening is working – I have comfort that we have systems and controls in place to measure that.
SAR automation is a no brainer. It is the most time-consuming job for the analysts, and I find it infinitely frustrating that SARs are not automated.
The existing system is a decades-old legacy system – firms have all the responsibilities and requirements to adhere to, while working with age-old processes. It’s time-consuming work. If I had a magic wand, I’d wish SARs into oblivion.
To learn more about how Cable provides Automated Assurance of your financial crime controls, get in touch with us here.
