The FinCrime Files – Q&A with Gregory Dellas, Chief Compliance & Innovation Officer at ECOMMBX

In our continuing series of the FinCrime Files, we caught up with Gregory Dellas, Chief Compliance & Innovation Officer at ECOMMBX.

Hi Gregory, could you tell us a little about yourself and your current role at ECOMMBX?

After a 22-year long career in the Cyprus banking sector, I am the current Chief Compliance and Innovation Officer for ECOMMBX, an electronic money institution licenced from the Central Bank of Cyprus. We specialise in B2B e-account management, cross-border payments and currency conversions. So, we mainly work with corporate customers from all over the world who want to use our innovative payments platform, ECOMMBANX to execute their payments, whether inward or outgoing, easily, quickly and at a reasonable cost.

In ECOMMBX I am responsible for the compliance programme of the company and managing the process of innovation and change management.

I started my career in Coopers and Lybrand in Nicosia and then joined Bank of Cyprus as a Private Banker. In the course of my career I held various senior and managerial positions in Cyprus Popular Bank and the Bank of Cyprus in wealth management, compliance and other areas.

In my previous role, at the Bank of Cyprus, I led the wealth management division of the bank, steering a team of over 100 people in private banking, institutional wealth, brokerage, asset management and global custody. Previously, I led the anti-money laundering (AML) risk management team within the International Banking Services Division and acted as the local compliance officer. My team was responsible for the onboarding of high-risk clients, the evaluation of large and complex transactions, as well as the review of existing and approval of new high-risk client relationships. In addition, I was also responsible for providing advice, guidance and specialized training to management and staff on AML and regulatory compliance matters. In the past, I also led the creation of private banking units in the U.K. and Romania and served as the group money laundering compliance officer, responsible for the AML function for Cyprus Popular Bank and all its overseas branches and subsidiaries.

You are Founder and Chair of the Association of Anti-Money Laundering Specialists (ACAMS) Cyprus Chapter. How important is working with ACAMS with regard to your day job?

My involvement with ACAMS started just over five years ago when I joined a couple of their conferences and was amazed and overwhelmed by the level of knowledge in the room and the decisiveness of anti-financial crime professionals to join forces and do the right thing.

I decided to join the effort and was very excited to be working with ACAMS to launch the Cyprus Chapter at a time when Cyprus was being questioned as regards its AML regulations and their implementation.

Since then, the Chapter provided me with the opportunity to network with like-minded professionals in Cyprus and abroad, accelerate my knowledge and experience in AML and TF but also introduced me to a number of people, I am now proud to call friends, who are also passionate to do something about stopping financial crime.

In the meantime, I also worked towards becoming CAMS certified, Advanced CAMS-Audit certified and a certified CAMS instructor. I was involved with ACAMS in the production of a number of their certificates and certifications as a subject matter expert including the newest CGSS and Advanced CAMS-RM certifications.

ACAMS produces great well-thought certifications but also provides a lot of resources for today’s AFC professional. There are free and paid webinars and a number of other free resources available. I believe all of these are important to keep one current and alert of changes in the regulatory environment. Also a lot of these resources are really practical, providing good reference for when working on your own risk management framework to fight financial crime. After all, we need to keep informed – as Albert Einstein once said “once you stop learning you start dying” – one of my mottos for most of my career.

What do you consider to be the current top 3 challenges today in fighting financial crime?

For me it is quite straight forward:

• Keeping up with regulations. Regulations keep increasing in volume and complexity. It seems that every time we feel we are on top of complying with one set of regulations, another regulation comes in, more complex and more demanding. I am not against regulation as I believe it is there not to punish financial institutions but, rather, to protect them from misuse. But the challenge here is to ensure you are aware of the changes on time and keep compliant without draining your resources. After all, we want the good clients to be able to perform their legitimate business through our institution and do it smoothly and efficiently.
• Keeping up with criminals that are evolving faster than we are. Technology seems to be helping anti-financial crime professionals, but it is also helping criminals find new ways of misusing the financial system for their criminal activities. You need to be alert, vigilant and, sometimes even, think like a criminal in order to keep up! There is a lot of information out there and the challenge here is to be able to quickly filter the good information from the noise and continuously step up your knowledge in order to stay ahead of the game or at least catch up with criminals at a reasonable pace that does not place you or your company in unnecessary risks.
• Keeping up with changes in technology. Technology cannot yet take decisions for us, but it can do a lot to provide us with the time to think, focus our attention on the real risks and allow us to take time to exercise judgment and take decisions. One challenge I see is how compliance officers today need to be aware of changes in legislation, need to think of ways to remain compliant but at the same time need to understand the evolution in technology to be able to appreciate how they can put it to good use. Compliance officers are asked to understand data modelling, thresholds, data management and structuring, statistical and business analysis and sometimes even computer programming!

What do you think is the most frustrating thing for today’s compliance officer?

Today’s compliance officer has become a focal point in most organisations, not only financial institutions. That means people rely on the compliance officer to provide them with opinions, answers to numerous questions, guidance and advice. This is quite flattering but it is not an easy job, especially for the less experienced professional.

Also, latest regulatory initiatives on responsibility and accountability seem to be more focused on who is to blame rather than what is to blame when there is failure. Accordingly, the environment for those working in compliance is becoming increasingly stressful, and stress brings with it a considerable amount of fear; fear of being liable, fear of loosing one’s job, fear being sanctioned.

That leads to mainly three things:

• overcautiousness when taking decisions
• submitting defensive SARs
• talent and knowledge moves out of the industry

Having 360° experience (both in the front line and AML compliance) I understand how challenging it is to find the right balance. And that is why I believe, compliance professionals should spend some time in the front line or first line of defence, and vice versa. It is important to understand each other and speak the same language when dealing with customers and their issues.

What compliance professionals sometimes fail to understand is that clients are good! We want the right clients in our organisation and compliance professionals should be encouraged by regulators and senior management to feel confident to use critical thinking and critical judgment, take calculated decisions and, at the same time, encourage others, across their organisation, to do the same.

What are your thoughts on the UBO registers that have been slowly released across Europe. Do they provide a useful resource, or do you have other opinions on them?

In my opinion, the UBO registers is a good step towards transparency. At the same time, I also see a few issues including:

• The validity/veracity of the information in the registers.
• The lack of clarity on the responsibility for keeping the information verified and updated and the consequences where there is failure to do so.
• I would be more worried for companies registered in more exotic (offshore) jurisdictions than companies registered in Europe.
• There does not seem to be uniformity in the application of the registers across Europe. Some jurisdictions outside the EU have implemented similar registers but a number of them are not fully transparent and some even charge a fee.

Having said that, it is a step in the right direction provided that the information on the registers is used to support the KYC process and does not replace it.

How has the current COVID-19 pandemic situation affected your day-to-day role?

Obviously as a Fintech we are very tech-centric and as a regulated company we have a full BCP (business continuity plan) in place. Accordingly, it was not difficult for us to adapt. We continued to be fully operational utilising the most modern work practices, ensuring first and foremost the safety and health of our staff, at the same time making sure our customers can continue to benefit from our range of services.

All companies had to adapt in this fast-moving environment. In the past, working from home was a luxury very rarely used in Cyprus. Now, most companies that can work from home do so provided they have the right systems and security in place.

Personally, I have not seen a huge change. Fintechs are traditionally more flexible in their processes and can easily adapt to change. As far as our services are concerned, there has been no downtime for our customers, at least for those who continue operating normally themselves (because obviously some have been affected), it is business as usual.

Do you think technology now plays an irreplaceable part in fighting financial crime, and do you see automation and machine learning as something that will, ultimately save you time and make your work easier?

I think technology is necessary nowadays with the way regulation is changing and demands are increasing. Technology can perform routine work for us, but it can also help detect red flags. So basically, technology helps enhance our pull of resources and become more efficient in how to deal with financial crime.

However, as previously mentioned, technology is not yet to the point where it can replace humans, but rather it can complement the work of humans and it can help humans do their job more effectively and more efficiently. Technology cannot think for us, it cannot yet exercise judgment but what technology can do is that can leave us with time to think, focusing our attention on the real risks and taking time to exercise judgment and take decisions. In that respect, technology is indeed irreplaceable.

On the other hand, we need to keep in mind that technology is also available to criminals who try to exploit it advantages and vulnerabilities to engage in crime and hide their ill-gotten gains. And to better take advantage of technology, it is vital for those working in anti-financial crime to understand how this can happen, in essence get in the shoes of criminals. 

Which key influencers/podcasts/blogs/books do you recommend to keep up-to-date with the latest developments in AML and financial crime? Or, where do you find inspiration in general?

Well, there are so many out there and Covid-19 brought about a spike in the number of podcasts and webinars available.

Obviously ACAMS is a great resource for me, including moneylaundering.com which is amazing for real-time information on regulations and AFC investigations.

I love listening to the new podcast series, Captivated Audience, run by Samantha Sheen of Exante Advisory Ltd, and a co-host. This was born during the lockdown and I thought it was a great idea and the information and opinions shared are really amazing. Also, C Notes, a webcast by Kevin Sullivan, author of Anti-Money Laundering in a Nutshell, is a new great series. I consider myself privileged to have participated in both of the above.

Also, I should mention the great Financial Crime Matters, from Kieran Beer of ACAMS.

I love the work of Kristy Grant-Hart who is very practical in her approach to compliance, helping compliance officers around the world to make their job effectively. And I am also looking forward to reading John Cassara’s new book on “​Money Laundering and Illicit Financial Flows: Following the Money and Value Trail”. John is the author of perhaps one of the best books on “Trade-Based Money Laundering”.

I also love watching money laundering related movies and series and also follow quite a few websites that share contents on current cases, analyses of fines and new regulations and legal requirements. A great movie for every compliance professional is obviously The Laundromat (released in 2019) with a great cast and a fantastic storyline. Also, Breaking Bad is an ML classic; I also liked Ozark, and I also recommend the latest season of Dirty Money from Netflix.