My Top Takeaways from the Women in FinCrime Dinner by ComplyAdvantage

By Denisse Rudich 

Advancing gender equality and tackling financial inclusion are key initiatives under the Mexican Presidency of Elisa de Anda Mazaro of the Financial Action Task Force (FATF). Launched in 2023 under the Singaporean Presidency, the Women in the FATF and Global Network looks to promote gender equality, diversity, and inclusion in the AML/CFT community.

ComplyAdvantage convened in-house compliance and anti-money laundering leaders from various businesses to discuss their experience as women in financial crime prevention. This included individuals from banks, payment service providers, e-money institutions, and foreign exchange houses who engaged in dialogue on emerging themes in the State of Financial Crime Report, shared their experiences as women working in financial crime prevention, and discussed the issue of financial inclusion across different regions. 

The evening opened up with a State of Financial Crime address, covering some of the current issues affecting the day-to-day work of AML/CFT and compliance officers. The world is currently changing at pace with massive ongoing digitization of payments and new value transfer methods, wars in the Middle East, Europe, and Africa, re-militarization, a Trump 2.0 presidency, and a rapidly evolving global governance landscape. The BRICS group of countries has expanded to include countries such as Iran, and the subsequent G7 will be held in Canada with a newly minted prime minister engaged in a trade war with the U.S. All of this is underpinned by an AI revolution, making it essential to keep the human in the loop on any AI-enabled process or control. The changes in ethical standards and norms, the shifting alliances, regulation in one country and de-regulation in another, the threat of ramping up and removing sanctions, and the normalization of abuse of power against a looming global recession means that there will be continued demand for financial crime professionals. Where there is uncertainty, criminality thrives. The State of Financial Crime report offers an invaluable source of intelligence, benchmarks, and general guidance for financial crime professionals. 

During the dinner, women shared their experiences, starting in the field and becoming MLROs, CCOs, and Heads of Financial Crime. Some shared that although the situation was improving with more women entering the field and around the table, there was a definite sense of awareness and isolation at often being the only female in the room where decisions were being made and that gender pay gaps are a persistent issue. A recent article in The Times found that “female leaders in finance earn 30 percent less than their male peers.” The importance of having access to a network of other women for mentoring, guidance, and advice was discussed, particularly to address situations such as negotiating salaries to ensure pay parity, moving to new countries to take up a new role operating in a different regulatory environment, access to advice on complex transactions or when dealing with unorthodox businesses and higher risk industries. Other areas discussed include challenges managing the day-to-day lives of women as wives and partners, single parents, daughters, sisters, primary carers, and individuals navigating physical changes and illnesses that are unique to 50 percent of the global population. Of note was how the acceptance of female leaders in this space could vary from country to country. Practical advice was given, resources and contacts shared, and a community was brought closer together through one night of fine dining and discussion. The FATF publication Breaking Barriers: Inspiring the Next Generation of Women Leaders provides invaluable advice from women and female allies working in AML/CFT to others in this field.

On the topic of financial inclusion, there was a robust discussion on the need to address women’s de-banking and economic access and ensure that firms in emerging markets have access to the same tools to prevent and detect financial crime. Across the world, there are 1.4 billion financially excluded adults, 54 percent of which are women. An article by the Gates Foundation found that women face significant barriers to using digital financial tools and services due to cultural norms, limited connectivity, lack of access to mobile phones, and low levels of digital literacy. 

At the same time, it is estimated that including women in digital activities could add $4.9 trillion to the global economy. On the issue of equal access to tools to detect and prevent financial crime, one participant highlighted the cost differentiation in tools developed in the Global North that are priced in U.S. dollars, pounds, or euros vs local value. Emerging market economies act as sources of illicit financial flows but face exchange rate volatility, and in many cases, it is simply not possible to invest in those tools, requiring the development of in-house tools or manual controls. For example, a contract in the UK for £1,000 would convert to an investment of Naira2 million in Nigeria, which is a significant and often infeasible cost to an established business and not viable for a FinTech or start-up. Purchasing price parity needs to be considered for lower-income economies. The FATF is currently updating its financial inclusion guidance to focus more on proportionality and simplified measures as part of the risk-based approach, build updated information on financial inclusion related to financial integrity, and best practice examples of the risk-based approach in AML/CFT. The consultation is available here. 

The evening wrapped up with an empowered community of rising women and current leaders in financial crime, having learned, shared, and built new relationships and future friendships.

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About the author

Denisse has over 20 years of experience delivering financial crime prevention, anti-money laundering, and counter-terrorist financing systems & controls across the banking and public sectors, including as Head of AML/CFT Policy for RBS (CBD) and Strategic Advisor to Rabobank. She has experience working with many top-tier financial institutions and the G7 and G20 Research Groups. Denisse is also a Technical Expert for the Council of Europe and an Associate Fellow at the Royal United Services Insitute. A native of Canada, Denisse has a BA in International Relations from the University of Toronto.