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