The use of sanctions as an international regulatory and compliance tool has risen exponentially in recent times. The increasingly complex nature of these sanctions programs has led to the need for qualified persons equipped with the knowledge to tackle the day-to-day compliance and operational duties brought on by the ever-changing rules that govern sanctions policy.
In order to gauge a real-life perspective of those in the business, the Association of Certified Sanctions Specialists (ACSS) has taken the time to ask sanctions professionals what they think is the best way of breaking into the sanctions field and how they see the future of the sanctions industry unfolding.
For this Member Profile, ACSS had a conversation with Joseph Bognanno, Vice President of Strategy and Alliances at Accuity. He is also the Chair of the ACSS Sanctions Innovation and Technology Taskforce (SITT). We sat down and spoke to him about his career in sanctions compliance, his expertise in technology and the work he has been doing on SITT.
ACSS: In your career, you have held many roles both in the private and public sectors, could you give us the highlights?
Joseph Bognanno: My background has always been within financial services with a heavy technology component to it. I started out working with core banking systems and basically implementing the IT systems that make banks run whether it’s checking accounts, savings accounts, credit cards.
Then in 2001, I had the opportunity to go to work for the Financial Crimes Enforcement Network (FinCEN), which is the US regulator overseeing financial crime compliance. That was sort of the start of my career combining the financial services piece, the technology piece, and the AML/financial crimes related technology. As part of the US Treasury and FinCEN, I worked in 40 plus countries implementing these systems that would support law enforcement and regulatory efforts to combat financial crime. I got to work with a lot of financial intelligence units, prosecutors, investigators and even compliance officers in the private sector during my time there.
Ten years later, I went back to the private sector and worked for a couple of software vendors. After that, I went to work for HSBC, and I was put in charge of a large team that developed, maintained, tested and validated all of the analytics systems that the bank used within the financial crime compliance area.
It was a pretty interesting and exciting effort to be involved with particularly because, at that time, HSBC was under a cease and desist order and deferred prosecution agreement. They were under heavy scrutiny by US regulators and to play a role in getting the bank out from under that was a big goal and a really great experience.
In 2018, I joined Accuity, where I am responsible for Strategy and Alliances globally. I provide input to the corporate strategy, develop strategic relationships with other technology and data vendors, manage innovative research and development projects, provide thought leadership and head our regulatory engagement.
ACSS: How did you become involved with the association?
Joseph: Throughout the course of my career, I have made lots of contacts both nationally and globally; Saskia is one of them. When she was starting ACSS, our company was one of the first to get onboard with ACSS. Because of my background on the technology side, Saskiaasked ifI could help formalize the structure of the technology taskforce. I’m very much an advocate and proponent of the association, so it’s been a real pleasure.
ACSS: Could you tell me a little more about the taskforce and what you Chair now?
Joseph: We call it the Sanctions Innovation and Technology Taskforce, or SITT for short.
We have a steering committee consisting of the Chair and six other members.We have “tech forums” where we invite other ACSS members to participate in discussions on technology within the sanctions compliance space, what the SITT is working on and our specific deliverable for the year.
Each year the taskforce makes a commitment to the ACSS Board to a deliverable that we will produce by year end. This year we’re working on a best practices book for applying technology to address sanctions compliance needs.We hope to be in the editing process by October, then get it into pre-production so that by early 2020 we will be able to deliver it back out to the association members.
ACSS: What advice would you give someone who would like to pursue a career in sanctions compliance?
Joseph: The advice that I would give is to take your core competencies that you have and figure out how you can apply it to this space because it is exploding right now. So, whether you graduate with a law degree or get a degree in IT, apply that core competency to sanctions compliance and you’ll very quickly become a leader in your area of expertise.
It’s such a growing field around the world. Financial institutions and even corporations are all looking to expand, tweak and fine-tune their compliance teams. They need to create efficiencies and ways to manage all of the risks that they may potentially be exposed to. They need professionals to put programs and framework in place and then, of course, apply the appropriate technology, process and procedures to support them.
It is a really open space. It isn’t a matter of “how do I become a sanctions expert?”It is more about taking your core competency and applying it in the sanctions compliance space where it can make the biggest impact.