ACAMS Today Magazine (March-May 2011) Vol. 10 No. 2 | Page 22

AML CHALLENGES contribute to or trigger an unscrupulous event. Lastly, corporate culture plays an important role. If the management chain of command shows a propensity to be weak, lazy or even border line unethical, then certainly the door is being opened and is seducing an employee who might be contemplating criminal activity. In a culture that is so bottom line results driven, it becomes easy to overlook the long term. How does management get to observe any potential personality changes or even become aware of an employee’s personal situation if there is little communication between them? There is no possible way to try to forecast a white-collar event if you have no clue who is your employee. This does not mean that management needs to take everybody out for a beer after the shift, but it should spark management to take a more proactive part in the ongoing concept of “know your employee.” Very few incidents can ruin the reputation a financial institution faster than a bad employee. Operational risk leads to reputational risk. Moving past the atmosphere, let us get to the crux of this and discuss some of the motivational factors and ideologies of a white-collar criminal mind. Keep in mind that many of the following qualities are interrelated and a person may exhibit several and/or bits of them all. • Greed: This is quite subjective. One person’s greed is not the same as another’s. Do I really need five Ferrari’s? However, the subject is motivated to obtain more and more objects of affection, regardless of the need or even the ultimate usage of the object. The desire for wealth is a ravenous appetite. • Need: Unlike greed, a subject may be at such a low point that he/she feels that the only way out is to steal. Gambling, alcohol or drugs may be underlying causes; however, once that door is opened, the slippery slope begins. The more that the subject does not get caught, the easier it becomes to continue committing crimes, even long after the subject has crawled out of the original hole. In another variation of need, the subject may be unable to admit the failures at the workplace and turns to crime to disguise those inadequacies. • Imitation: The subject becomes aware of other people doing bad deeds, so he/she 22 wants to show that he/she can do it too. The semi-glorification of wrongdoers by various media outlets does not help. The hiring of a black hat type prior criminal to review your systems may seem to have some merit; however, it may have an inspirational effect on the subject. • Resentment: A subject may have determined that he/she is worth more than he/ she gets paid, or feels that he/she has been treated poorly or disrespected in some way, shape or form. He/she then feels that he/she is only taking what he/she deserves. • Opportunistic: Sometimes if the stars align just right, the self-discipline is low and the opportunity reveals itself, the subject will take the risk. He/she may fall in love with his/her own particular financial strategy and become obsessed with it and determined to prove that it works. When it does not, opportunity turns to need. • Gratification: Money is not the motivating factor. The act, in and of itself is what motivates this subject. The game is the most important thing. • Validation: The subject excuses his/her own actions and believes that he/she has done no wrong. He/she has no apology for his/her actions and anyone that was hurt due to his/her actions were wrong for getting in his/her way. He/she feels little to no guilt. He/she may dehumanize any event and believe that no real person was hurt. • Superiority: He/she feels that he/she is the smartest person in the room (and he/ she is very intelligent) and he/she is entitled to anything that he/she can obtain. The subject feels that he/she is above the law, and certainly above any rules and regulations. He/she believes that he/she has a higher purpose and ethics need not apply. He/she has the knowledge of how the system works and can manage to fly under the radar. • Ego: An offshoot of superiority, the subject seeks ego gratification by outsmarting his/her bosses, the system and even the authorities. However, at the core of his/her being is a sense of inferiority that must be nurtured by external successes. • Power Dominance: The subject loves the control and the admiration that goes with it. The subject circulates in powerful ACAMS TODAY | MARCH–MAY 2011 | ACAMS.ORG circles and easily mingles with other power brokers. • Addiction: The subject seeks out risk and the adrenalin that goes with it. Each day the system is overcome, new crises to conquer are needed. • Responsibility: When things go wrong, it is not the subject’s fault. Clients may be blamed for their ignorance, or blame shifted to other employees, organizations or on the government for too much or too little regulation. • Critical Mass: The subject, when confronted and/or cornered, will attempt to redirect interest away from the real issue and focus instead on a different topic or even on the confronter. This allows the subject to maintain a guilt-free perspective. In summary, there is no sure fire method to determine if a person is or about to become a white-collar criminal. However, those criminals who have been captured do tend to exhibit similar behavior patterns. Much like using good interviewing techniques and reading body language, there is no single character descriptor that is the panacea for discovery. Reading various profile characterizations is simply building blocks that when added together creates nothing more than potential warning buoys. The lesson here is for management, upper level management, boards of directors, the financial gods or some white-collar crime fighting superhero to adopt a proactive approach to white-collar crime. Written policies and procedures should be created, developed and implemented, and this risk should be managed as you would any other type of risk. Institutions should advance concepts such as team building, and critical thinking. How do you adapt to change? Reflect upon your own trust behaviors. Develop strategies for creating leaders and not just managers