Rajat Gupta: Daily Insights from a Compliance Officer

Rajat Gupta

ACAMS member Rajat Gupta, CAMS-RM, recently took the time to speak to ACAMS Today about his career. Gupta is a compliance officer at the Bank of Baroda Dubai in the UAE, where his responsibilities include ongoing alert monitoring and due diligence through the statistical analysis system (SAS); investigating alerts and the filing of suspicious activity reports/suspicious transaction reports (SARs/STRs) to the Central Bank of the United Arab Emirates (CBUAE); acting as a liaison and responding to the company’s U.S. correspondent bank’s compliance department queries, alerts and report inquiries; and assisting in developing, initiating, maintaining and revising policies and procedures for the general operation of the Bank of Baroda’s compliance program. In addition to his Advanced CAMS-Risk Management (CAMS-RM) certification and Certified Anti-Money Laundering Specialist (CAMS) designation, Gupta also holds other certifications from ACAMS: Certified Global Sanctions Specialist (CGSS), Certified Know Your Customer Associate (CKYCA) and Certified AML FinTech Compliance Associate (CAFCA). He holds a bachelor’s degree in information technology from India’s Manipal Academy of Higher Education.

ACAMS Today (AT): What inspired you to pursue a career as an anti-financial crime (AFC) professional?

Rajat Gupta (RG): One needs to be inspired to have a purpose, and my purpose for wanting to be an AFC professional is because it is a noble cause. That is what draws me to it and generates a passion in me. For every single piece of currency laundered, there is a victim. Therefore, we, as AFC professionals, have a moral responsibility to adhere to the “three s’s” of the profession by saving societies, saving institutions and saving countries.

AT: What takes place during your typical workday?

RG: Being an AFC professional requires that I stay abreast with daily changes in the market, as new ways to launder money are invented and used constantly. So, I start the day with a cup of tea while scouring through the newspapers and websites to discover what has happened while we were asleep. This helps me to be up-to-date on the evolving methodologies of illicit actors. Sometimes, there is some information on one of our customers involving some emanating activity, and there is a “bomb” for the day! If that is the case, we begin an investigation of the customer, searching the institution’s database, conducting transaction analysis, etc. Otherwise, the day will concentrate on transactional analysis, transaction investigations, STRs and the like.

AT: What is the most rewarding aspect of your work?

RG: The most rewarding aspect is when I am able to unearth any illicit activity. It gives me immense satisfaction that—to an extent—I have utilized my skills to save my institution from illicit actors and further saved the victims of these activities.

AT: Could you share any recommendations on how to best collaborate with other departments at your institution, with law enforcement (LE) or other AFC professionals to help with your department’s goal of fighting financial crime?

RG: In my opinion, everyone’s role in the institution is crucial. All stakeholders are important in this fight, and we should include their input. Because front-line staff members are the eyes and ears for compliance, they should be better able to relate to compliance and understand their purpose to that end. So, meeting them, training them and listening to them should help in collaborating across departments in our fight against financial crime and meeting the objective. As for LE, we should also have transparency. The thorough study of the cases currently under investigation, and our response to them as financial institutions (FIs), should be clear, concise and submitted in a timely manner. This helps to build a good rapport with LE.

AT: Which type of financial crime do you believe is most critical for FIs to focus on and why?

RG: Every financial crime is critical. However, from my experience, I have observed that for almost all predicate offenses, the launderers and sanction evaders use trade-based money laundering (TBML), as this is difficult to detect and easy to carry out. Crypto has also seeped into the TBML world for payments for trade.

AT: Do you have any insights from your career that you would like to share with other ACAMS members?

RG: ACAMS is doing wonderfully well in evolving minds and raising awareness around financial crime across the globe. I feel that AFC professionals should have a thorough understanding of how to work and conduct the operations and transactions in an FI—the practical aspects of working in an FI—and continuous learning will help AFC professionals undertake a 360-degree view. This should help develop better compliance controls and understanding.

Interviewed by: ACAMS Today editorial, ACAMS, editor@acams.org

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