Dan Soto: Tips for Success From an AML Compliance Professional

Dan Soto

As an active and visible Association of Certified Anti-Money Laundering Specialists (ACAMS), American Bankers Association and BSA Coalition board member, Dan Soto is enjoying a fulfilling career in compliance. As chief compliance officer of Ally Financial and at previous compliance professional jobs at other key firms, Soto has had the opportunity to experience compliance from many perspectives—in a good economy, in a downturn, from the Bank Secrecy Act (BSA) officer perspective responsible for day-to-day compliance and from the executive perspective responsible for firm-wide compliance. In Soto’s tenure, he has also dealt with a wide range of Bank Secrecy Act/anti-money laundering (BSA/AML) issues from banking high-risk customers, automation, and technology in BSA/AML and beyond.

With Soto’s enviable positions and experiences within the anti-money laundering (AML) and compliance industries, he has a lot to offer when it comes to advice for success in the compliance profession. It is important to think about your career in a strategic way and consider what experiences you may want or need to meet career goals. This article may provide ideas to consider when planning for your own.

What struck me first when I met Soto was his intelligence, positive energy and kind demeanor. There is just no denying it, he is a charmer! His charisma aside, Soto’s work ethic, various roles within compliance, and dedication and commitment to AML and compliance have led to a satisfying career. Interestingly, Soto does not view himself as successful. Rather, he said, “I view what’s been accomplished by a lot of people with whom I’ve worked and interacted as a success.”

As I mentioned, Soto is currently the chief compliance officer for Ally Financial, where he is responsible for Ally’s enterprise-wide compliance activities, including AML compliance. Before joining Ally, Soto spent two years with Wachovia/Wells Fargo in AML and retail banking compliance; was the chief compliance officer for Royal Bank of Canada–Centura for three years; and spent eight years with Bank of America in the global AML compliance function.

Prior to joining the private industry, Soto was in the public sector as a commissioned bank examiner, where he spent six years with the Federal Deposit Insurance Corporation and nearly ten years with the Federal Reserve Board. As a bank examiner, he learned from the financial crisis. At the Fed, Soto shared his knowledge to impressionable examiners as a trainer and later focused exclusively on BSA/AML, working on special investigations in the era of know your customer.

Soto is based in Charlotte, North Carolina; is a faculty member of the American Bankers Association’s National Compliance School; and is on the Association of Certified Anti-Money Laundering Specialists (ACAMS) and BSA Coalition advisory boards.

Almost as much for selfish reasons as for this article (because I am embarking on a new role within the BSA/AML space), I asked to interview Soto to learn his secrets to success. Here is what I learned from him.

Soto on AML and the Current Landscape

Given the opportunities Soto has had relative to AML issues, I asked him what he thought about a few often-discussed BSA/AML matters. His overarching view is that you cannot be successful in attaining the mission of BSA/AML “in a box,” so to speak. Soto has come to believe that partnerships and information-sharing among bankers, regulators and law enforcement are critical to detecting money laundering and successful prosecutions.

Soto is currently the chief compliance officer for Ally Financial, where he is responsible for Ally’s enterprise-wide compliance activities, including AML compliance

Soto believes that while technology and transaction monitoring systems are critical to the industry, for efficiency reasons they need to evolve. Soto commented that transaction monitoring is sometimes like “searching for a needle in a haystack of needles.” He commented, “Time will tell if artificial intelligence is the answer. Right now, we are craving more efficient results from transaction monitoring.”

After learning his thoughts on key issues, we transitioned to his career and how he has been able to make such a contribution to the AML industry and to his employers’ success in compliance. I asked him what he would tell others aspiring to a successful career in BSA/AML.

Soto’s Tips for Career Success

First and foremost, Soto commented, “Have a passion for BSA/AML. Ask yourself why you’re working in AML. If it is merely for a paycheck, then consider that it may not be the career for you.”

Soto also recommends getting your feet wet. He said, “Secure a position in AML which you believe can teach you and give it your all. Work hard and learn as much as you can from the role.” While doing so, build relationships and trust, and get to know people with whom you work. According to Soto, this is very important. “These relationships may or may not be important later on, but either way, you have a new friend,” he commented. “I have never met a stranger, and when I say hello I really mean it. The key is to keep learning and building relationships.”

Along the same lines of building relationships is Soto’s belief that you have to work well in a team setting. Soto points out that teamwork toward a common goal is critical in compliance. This fits with his belief that his success is really the success of others with whom he is working.

Soto has observed that a roadblock for some in business is making decisions. He believes being able to make decisions, even without every last piece of data, has worked to his advantage. “I’ve been lucky that in most cases, my decisions have been the right ones,” said Soto. “I’ve learned a lot, however, from the decisions that have not been successful. Either scenario is a win because you’re learning.”

According to Soto, another key to success is putting yourself in others’ shoes. “Putting myself in this position forces me to listen and to get a different perspective on the matter at hand. I’ve found this enlightening in several instances over my career.” Soto also said, “You don’t always have to lead from the front. If there’s an issue that needs resolution, use your relationships to connect those on different sides to discuss the issue; be a mentor.”

Final Thoughts

Soto believes that while technology and transaction monitoring systems are critical to the industry, for efficiency reasons they need to evolve

Soto’s journey in AML compliance has taken him to different places all over the world, and has enabled him to work for different organizations in different roles. It has empowered him to contribute to the U.S. Treasury Department’s very important role of protecting the U.S. financial system. The combination of his work principles, a belief in what he does, and opportunities he has had have shaped him into the successful executive he is today. As I transition into my new role, I will be thinking of Soto’s career philosophy and sage advice. I hope to emulate in practice his catch phrase, “I never met a stranger and when I say hello I really mean it” as this seems like a formula not only for building a satisfying career, but a satisfying life. As you embark on a career in BSA/AML or strive for new challenges in your job, consider adopting some of the items set forth in this article. They are certainly worth a try.

Elaine Yancey, CAMS, MBA, large bank examiner—advanced, Federal Reserve Bank of Richmond, Richmond, VA, USA, elaine.yancey@rich.frb.org

The views and opinions expressed here are those of the author and do not represent an official position of the Federal Reserve Bank of Richmond or the Federal Reserve System.

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