The Compliance Word

S1E5: Malcolm Wright

April 07, 2021 RAW Compliance
The Compliance Word
S1E5: Malcolm Wright
Malcolm's Career
People Must Learn To Adapt To Change
Innovation and Bottleneck
Regulatory Change
How To Spread Knowledge
Malcolm Fun Facts
What Keeps Malcolm Going?
RAW Compliance
The Compliance Word
S1E5: Malcolm Wright
Apr 07, 2021
RAW Compliance

In this week's episode, Malcolm Wright joins us to discuss his non-traditional career path and the importance of adapting and embracing change. Malcolm Wright is an influential business leader and he has worked for companies such as Revolut and Diginex. He also has a background in products and technology. 

Hosted by Oonagh Van Den Berg and edited by Luke McCann.

Show Notes Transcript Chapter Markers

In this week's episode, Malcolm Wright joins us to discuss his non-traditional career path and the importance of adapting and embracing change. Malcolm Wright is an influential business leader and he has worked for companies such as Revolut and Diginex. He also has a background in products and technology. 

Hosted by Oonagh Van Den Berg and edited by Luke McCann.

Intro 00:02 


Welcome to the RAW compliance podcast. Each week on ‘The Compliance Word’ host Oonagh Van Den Berg will meet with practitioners from across the industry, public, private, and FinTech reg tech providers. They will honestly and broadly discuss topics impacting risk mitigation in financial services, financial crime, and how we can build a sustainable and credible compliance culture. Our aim is to empower listeners with the knowledge and skills to tackle these problems and promote positive change to the global compliance community.


Oonagh van den Berg: 00:50 


A massive thank you Malcolm for taking the time out of your incredibly busy schedule. Our listeners will get an idea of how busy you are, as we go through today's podcast. Thank you for joining us last week to help with the free training on the masterclass for the crypto regulations. It was incredibly kind of you to do that because I know just how busy you are. So thank you!


Malcolm Wright: 01:16 


Thank you Oonagh, it's a real pleasure!



Oonagh van den Berg 01:20



I've known you for a few years now and one of the things that I didn't know about you is that you are a published author.


Malcolm Wright 01:32 


Yeah. So, I won't go back into my history too far, but in the 90s, I wrote a piece of software that did quite well at the time and was on cover CDs. These are the days that you had CDs that were attached to the outside of magazines. I also wrote a piece in the Reg Tech book that came out a couple of years ago now. It looked at the intersection of artificial intelligence, and how that can benefit the fight against financial crime and some of the risks around that. In between that time, I have done a few articles. I used to write for a magazine that looked at things like search engine optimization. I used to write a lot about search engine optimization and how to get to the top of Google, things like that. So, it's been a varied path to get to where I am now. 

Oonagh van den Berg 02:29 


With many of our guests that we have on, one of the questions we ask is; ‘How did you get to where you are today? Looking at your background, you did start in technology. I suppose that makes complete sense that you have ended up as a Chief Compliance Officer of one of the largest crypto firms in the world. You have gone from being in tech to Thomson Reuters, you were a specialist in AML and transaction monitoring. You have worked at Revolut, Diginex, and in your current role with 100x group. In between as well, you are working with several international bodies, advisory bodies, and building regulation frameworks around cryptocurrency, and talking about decentralized finance and what we can do as an industry to help protect investors. I do not know if you want to jump into that right now or if you want to talk a little bit more about yourself? I think that your career is such an interesting one. I think like many people, there was not a natural path. But it all makes total sense when you look back now.


Malcolm Wright 03:47 


I think at the time, it might not have made much sense. When you leave school, you are taught to go to university, study for a degree, and then go follow that career path. Very often, the interview questions are ‘where will you be in five- or 10-years’ time?’. You think maybe I will progress in the company or another company, but I will still be doing the same thing. I remember I met a business author called Charles Handy back in the late 90s. He used to write about something called a portfolio career. Which looked at the idea that you would not be necessarily doing one thing. That kind of appealed to me because I like to try new things and see where that will lead me. So, each steppingstone was really into something new. To arrive at the point where I am now kind of intersection between technology, compliance, legal entrepreneurship has come together in a very nice, sweet spot for compliance for the future of finance, for the next generation, and having to have that awareness of those different pivots. So, I would say to anybody, do not be afraid to try something new. If it feels right to do it, then do it. You know, with RAW and your own consulting firm and everything. So, I think that it's certainly something to be embraced when the opportunity for change comes along. If it feels like it is the right thing to do, then jump and see where it takes you. 

Oonagh van den Berg 05:36 


I could not agree with you more. Recently now with putting together my own consultancy firm and RAW Compliance. I feel like all the stars have aligned. And I realized why I needed to have all these different experiences in my career because everything just makes sense. I needed to learn this. Sometimes, as you rightly said, it is jumping in the deep end. You do not know whether you are going to be able to swim or not, but you have got to have enough confidence in yourself to know that you are going to be able to make a good go of it. In some of the positions that I have jumped into my career, I literally jumped in the deep end, and I have had to upskill overnight. For example, today, I have been putting together materials for our crypto masterclass this week, and it is focused on building the compliance framework around a crypto firm. And the section came upon the skill sets of a compliance officer. I was sitting there understanding a completely different profile from a traditional bank that we need somebody in your role to have. You have that profile. You have been in the technology, you have been in the advisory of the AML, transaction monitoring responses, the key areas that we need to be looking at. But very few people are going to have that blend of background. That is one thing that I suppose concerns me slightly about how we are going to upskill people going forward. But secondly, people like yourself, how do you foresee how we're going to be able to educate people, to get them into the roles, and doing the right work with the right skill sets? 


Malcolm Wright 07:23 


I think it very much starts with the individuals. It starts with the listeners here, for example. There must be a desire to say, ‘Okay, I'm ready to change, to grow, to learn things that are new.’ I know a lot of people have a fear of technology. I have spoken to many people who say, but I am not a technologist, I cannot possibly learn this. And then once you ease into it, it is not a case. For example, in the work I do in a FinTech firm, you must understand the intricacies of how blockchain works. Or you must understand the intricacies of how nonface-to-face onboarding technology works, but it is about having an appreciation and understanding of the risks. I think that when training comes in, it's being able to train against those risks and say, ‘Well, here are the myths and reality of a particular use of technology. Here are the risks that they can create, and then having that interest to learn those skills, and then maybe to apply them in a work setting. I think what is important, and it goes with the earlier point about having this sort of career of different paths. It is having the mindset that says, I am willing to do this, I'm willing to extend myself beyond this, rather than say, well, I've always done sanction screening, that's all I'm going to do. The future of the compliance role is going to look very different from what it does today. And, I wrote about this, about three years ago. I wrote a piece for the (ICA) The International Compliance Association on this, which did look at the skill sets of the future. You will have to have an appreciation and understanding of technology and not to be afraid of it but be willing to just sort of embrace the different aspects of it. 

Oonagh van den Berg 09:23 


That is something you kind of hit the nail on the head there. People do get too comfortable sometimes, especially in large organizations where they become siloed. People say ‘I do sanctions, or I do KYC, or I do transaction monitoring. I have been incredibly blessed in my career to be able to work across the entirety of compliance. I have built control rooms; I have been front office advisory. I have built AML frameworks. I have done employee licensing. I have done regulatory approvals. But we do have a lot of people in the industry who say, I have done sanctions. And that is all I have really done. And the thing that I was thinking a lot about today was the future skill sets and the needs of a compliance officer. One of the things we thought about doing with RAW was building a compliance training program where over a year, we can train people up to become compliance officers within FinTech, some within crypto firms. And I am starting to think more and more that this is something that the firms themselves would pay for. We just thought that there seems to be a need for this in the industry. If you are working in law or accounting, they have these industry programs where you can join them to train as a lawyer to train as an accountant, but we do not seem to have that within compliance. And now more than ever, especially in the future world that we are going into, I think we need it. It's something that we were going to bring kind of to the table in the next few weeks to start talking with people like yourself about whether there is a need and whether there's an appetite for it within organizations. 

Malcolm Wright 11:11 


I think there is a need, it's somewhat geographic to a certain degree. So, if you looked in certain jurisdictions, you would find that there's more opportunity. So, in London, for example, the FinTech scene exploded quite quickly. And there were a lot of opportunities. And once you are in that sort of environment, you do not stay just doing sanction screening. You might go in, for example, just doing KYC, and then expand into transaction monitoring and risk assessments and grow within that role once you are in. In other jurisdictions, there is a much more traditional financial sector. Virtual banks have not emerged fully yet to really see that ecosystem explode. So, I think that is where some training could be helpful. I mean, you have, for example, Hong Kong, if you did an open FinTech course or something similar I think that would be wonderful. Because it does give that option to explore at your own time and monitor your own progress and to expand into a new area and gain that new knowledge. Then once those opportunities arise you can say, ‘Well I’m ready to apply for that job. Because at least I have got a fundamental understanding, and I can now grow into the experience side of it, and then do it.’ It may also be that we see traditional finance starting to pivot because as we get more pressure from the new Fin Techs who are coming in with a lighter or differentiated approach to compliance that uses much more technology-driven, then perhaps some of the traditional financial sectors may also follow suit. I am not talking in the next one to two years, but maybe five to 10. The experience and the opportunities then could exist in the traditional financial sector as well. 

Oonagh van den Berg 13:20 


I could not agree with you more. It is frightening. I will be honest a few months ago, I have been working with a FinTech in the UK to help them build first to get their licensing, their FCA license, and then to build their compliance framework. I was sitting there one evening putting together this the traditional way that we would put together and build a compliance framework. And suddenly, I had this overwhelming moment, of literal nausea, where I realized that none of what I was doing would work. Because the product has been built from a technology perspective. So, we need to build the infrastructure for compliance and for risk controls. Also, from a technology perspective, and policies and procedures, well, policies, they’re nice to have, but they're absolutely meaningless if we can't operationalize them. I realized that the infrastructure was not there to even operationalize them. We did not have the systems; we didn't have the people. And it was a five-man band pulling this all together. It was quite a frightening moment. I have been in the industry coming up 20 years. I have seen it when it can go wrong. You realize that junior compliance people going into Fin Techs. They do not know what they are stepping into, it is like Pandora's box. It was quite a frightening experience for me. That is coming from someone that has been in the industry a long time. It was a massive learning curve for me. I had to rethink and re-strategize just how we build a compliance framework. It was a big moment to suddenly realize that we just must do it in a totally different way. You are working in one of the most well-known FinTech crypto firms in the world. You have worked with Revolute, and you've worked with Diginex but where did you start? Did you go in with an understanding of these key risk areas? 


Malcolm Wright 15:54 


I think it is fundamentally the same. I think Revolute is such a great example of a change in the way things are done, and how that can help. And what I noticed there was how compliance can go from being (as a good friend of mine once said) the business prevention unit, into becoming a business strategy driver. Revolute got their retail onboarding down to around three minutes, non-face to face with full KYC, which at the time was unheard and I think now it is down to about 18 clicks or something like that. If you look at how long it takes to open a bank account with a traditional financial services firm, you kind of go that is a big gap. That is a big gap to breach. But it shows how compliance can integrate and work with business alongside the business to say, ‘Okay, how do we do this smart? How do we do this in an efficient way that can really drive good outcomes for the business without losing the essence of what compliance in this context, the AML CFT compliance is about.’ And moving into the same footing in whichever role I go into, is very much going to be okay, what are we doing? Well? Where can we do better? It is those kinds of questions that you ask. And that is back to my development days. So, when we were looking at technology development, and we finished a sprint of code over two or three weeks, then we would do a retrospective and say, Okay, what went well, what could we do better? And the same thing applies to any role. So, as you walk into the office tomorrow, you could say, well, what did I do? Well, yesterday, on a personal level, what can I do better? What did my team do? What can we do better? So, I think those two questions can serve not just in the development sphere but, when you're leading a team of compliance people, when you're looking at how to improve your processes, across the piece, I think that is, it's a great way to sort of stand and assess where you are today. And then where you need to go tomorrow. So that you do not repeat the same mistakes of the past, but you just move through. And can constantly iterate upwards in terms of your improvement. 

Oonagh van den Berg 18:21 


I could not agree with you more. I am a big believer in creating frameworks that are effective and efficient, and that is also sustainable, but also agile. I think that we constantly need to take a step back to look and say, what are we doing well that works and what is just not working? When we are monitoring for risk, we are just not looking for risk, we are looking for changes and client profiles that potentially are cross-selling opportunities. We are looking for ways in which the client's behavior is changing, to possibly enable us to sell another product to the client. We are always focused so much on identifying the risk of money laundering, all different types of risks, but we should be looking at this as a revenue, benefit, or revenue generation ability as well. When I was working with the FinTech, we had the same conversation a couple of months ago on client onboarding. And we are doing the screening, and I was like, but we are going to create a bottleneck because how are we going to be able to clear those screening alerts. We will lose customers if they cannot instantaneously get the credit. They will just go somewhere else, and there are other providers. So how do we keep the regulatory requirements and the standards in place but also move this around as quickly as possible? The requirements for proof of address is something so simple, but yet the target audience of the product is 18 to 30-year-olds, and these guys use paperless accounts. They do not get letters or statements anymore, everything is downloaded. But you're not allowed to receive a downloaded copy. So, they came up with an interesting way of pinging via GPS. The individual will upload proof of address, it is a regulatory requirement. They will use a system to ‘ping’ the individual. And again, it is things like this where they are just trying to be innovative. But then sometimes the regulations are not moving as quickly as we need them to move in order for us to be as innovative as we need to be. 

Malcolm Wright 20:38 


That is true. Crypto is a great example of the breakneck speed at which something can change. But COVID, as well. So COVID has led to us having to think about new ways to onboard customers. How do we really embrace non-face to face onboarding and straight-through processing of screening? And that experience from going to, ‘I'm just about to sign up for this service to ‘oh, I can use that service.’ That as you said, they will go elsewhere, if it's not more or less instantaneous. Because we've (particularly in the age group) moved to an instant culture. So, there is a demand. Now, that means we must think about things in a completely different way. And so, phrases like, ‘well, this is the way we do it around here, it just doesn't work anymore! We to rethink what we are doing. I think you mentioned earlier about the stuff I sort of do, alongside regulators and so on (the international agenda). I think there was a recognition that we do have to move quicker towards this change that is coming, and proof of address is a great one. Because as you say, you can download proof of address, but you may not be able to accept it. But there are other ways of verifying addresses. So yes, I think that there are two things that come to mind. There needs to be a greater flexibility or ability to change from the regulatory community, or policymakers so that they can adapt to this breakneck speed at which the world is changing. And I think that there must be a greater participation between the industry, whichever part of the industry that is so not just traditional finance, or FinTech, or crypto, and policymakers and regulatory and law enforcement. And this is something we will certainly be doing in the crypto world over the last two years. And it has really been very successful, where it has been embraced.


Oonagh van den Berg 23:05 


Very conscious of different regulators. We have rules-based regulations, which are very slow to change. Most locations now, we have a blend of principles and rules-based regulation. And unfortunately, in the AML space, a lot of it is rules based, we do have quite prescriptive requirements. When you talk obviously about to kind of public private partnerships on the industry feedback to both regulate both local regulatory and international bodies, such as FATF. We need to quicken the speed at which we are making these changes happen, because they are just not practical. Some of the requirements just do not work anymore. And the interesting thing with the GPS was, will the regulator allow us to circumvent the requirement for proof of address by doing that? And his response was; if you are a drug dealer, or you are involved in human trafficking, do you really want anyone to know where you are? You are not going to want to be pinged. In effect, it is a greater deterrent to you being used for illicit activities, because people do not want you to know where they are. So that was an interesting discussion point, because there was a much more benefit in that than a proof of address that somebody could falsify in two seconds. You are one of the founders of the V 20. You work with FATF and you're doing so much work on the international arena. You are instrumental in driving regulatory change. How do you see that we as an industry can participate in the regulatory change and influence the change and the right changes? 

Malcolm Wright 24:58 


The crypto changes with FATF it was unique timing that happened just at the point where the group I am working with (global digital finance), the AML working group had been running for about nine months. It was just at the point I have taken over as the co-lead. And then the FATF said, ‘hey, we've got these things, virtual assets and virtual assets, service providers and user consultation’. And that was where it really began. And so, we rallied the industry to respond to that. There were similar groups in the US, and that matured into further pieces of work, where we collaborated with one another. But also, we have had the FATF’s attention. They put together a virtual asset contract group to reach back out to us as an industry. So, we had that bidirectional conversation. Now, certain regulators are also very willing to engage the industry, recognizing that it's moving so fast, that there's a need to actually talk to the industry to understand what's happening, so that they can then say; Okay, well, how do we solve this? Do we solve this through guidelines? Do we solve it through regulation? What is the best approach and, in some cases, it's a blend of both? I think the more flexibility you can build into regulation, that it then becomes the regulator. Then they can apply appropriate guidelines, that gives the greatest ability to change or change direction or update guidance quickly, rather than saying, ‘Okay, we must go back to the legislators and, go back around the circle again. So, the time it takes to put something through legislation, the world has already moved on. So, the more flexibility the regulators are given to, to being able to implement appropriate regulation, the better. And the more that they are willing to reach out to the industry to understand not only what the framework is and also what the industry is doing, what the challenges are, what the exposure is in terms of AML and CFT risk. But they could also work in the wrong direction. So, we see the industry can understand from regulators what the expectation is to comply and can then go away and think about what the most appropriate technology solution might be. Is it technology that would be to solve that particular problem? I think it starts locally, if there is a local group that interacts with the regulator, and I do not want to say lobby, I think interacts it has to be almost a partnership between industry and regulators, then there can be regional bodies as well. Then you can go up to sort of the global bodies like GDF in the crypto space, but equally, you have payment Association groups, such as the EPA, which is an Asia and Europe as well, that will do some of that outreach. Set up working groups, set up roundtable events, webinars, produce white papers, all those kinds of good things that can really help to educate, whether it's regulators, whether it's individuals, the public, or whether it's the industry itself. But you can produce this, there is a great way to sort of produce a collaboration between those that are putting the governing controls in place and those that must implement them. Because ultimately, the goal is the same. It is to prevent financial crime from taking place or to mitigate the risks of financial crime from happening within the financial ecosystem. So, if we are all fighting from for the same outcome, then would not it be great if we can talk and come up with a combined approach that works for everybody? 

Oonagh van den Berg 29:15 


I could not agree with you more. I remember very early in my career; I did a legal internship with the European Central Bank.  They have a lawyer for every European country and because I'm from Northern Ireland they didn't have anybody to cover the UK or Ireland at that time. I got positioned as the adviser to the Bank of England and the Central Bank of Ireland and I just left University. I was what 24-25 years old. At that time, I thought I knew everything. And I quickly realized that whilst I am very good at reading regulation. I did not know products and if I did not know products, I was dead in the water because I needed to be able to interpret the regulation into the product language. That is something I am incredibly mindful of, especially as we have been doing this crypto masterclass. If you want to understand how the regulations are going to work, you really need to understand the product. And I have been surprised at the number of people that have held themselves out, as SMEs in this area, and by the way you are an SME. The likes of Benedicte Nolans as well, you guys are phenomenal at this. But there are a few people who don't even understand the ins and outs of how Bitcoin or even ICO principles of how they actually work. But if you don't understand the product, you're not going to understand how the risks exist within the product, or indeed how the risks could present themselves. You have a fountain of knowledge. And obviously, you have built this up over the years, you've been around, since the inception. Hiring people today that are going to step into these roles, going to be able to come somewhere close to the level of knowledge and experience you have for not just the product, but obviously, what is needed to mitigate the risks. 

Malcolm Wright 31:12 


The closest comparative I can give is something like science, where we've advanced science over the years, but in order to learn a particular scientific field you do not have to go all the way back and start from the beginning. Let us say the Einstein's theory of relativity or something like that, you can draw on that knowledge, and then every subsequent piece of knowledge after that. Then take a further direction beyond the combined aggregate knowledge of everything that has happened. So, whereas we spent two years or more sort of beating out the path, what compliance will look like for crypto, in this case, somebody coming in today will be able to aggregate that knowledge much more rapidly, because this was done in a linear fashion over time, and where we have actually been working through it. Now we have a lot more of the answers. So, somebody coming into it could aggregate that knowledge. Let us say the RAW compliance course, now is a great place to start. The last couple of sessions have been good. And then they are already up to speed on what took us several months or more to get to that point in just a couple of hours. So, somebody coming into it with the right mindset, with the right attitude, having built up perhaps a little bit of knowledge on the side on, let us say, technology, or various aspects of compliance that are relevant. There is no reason why they then cannot come into the conversation say, well, hang on a sec, I've studied compliance. I think I can add to this conversation. This is what we what we could do next and augment on what's already been built. So I don't think it's a case of somebody is going to have to say, well, it took us several years to get to this place, it's going to take me several years, and then a few more. They will be able to aggregate on that knowledge. And then, you know, springboard from it to reach their own potential. 

Oonagh van den Berg 33:26 


Now for some fun facts about Malcolm. So, I love reading people's LinkedIn profiles. Obviously, people describe themselves, you have your recommendations and then languages. I did not know that you spoke Greek. This is one of the things I wanted to say today. I never knew this about you before. 


Malcolm Wright 33:53 


Yeah, I lived in Greece for 10 years!

Oonagh van den Berg 33:56 


When you were young, as a child, or as an adult? 


Malcolm Wright 33:58 


As an adult. When I ran my own company for a while. And the company was based in the UK. I had staff in the UK. But Greece was less than three hours flight away. So, I was super commuting back to the UK, but I fancied living somewhere where it's warm and sunny, rather than necessarily a little bit grey and miserable some of the time. I chose to live somewhere where it was warm.

Oonagh van den Berg 34:30 


Whereabouts in Greece?


Malcolm Wright 34:32 


In the north of Greece. 


Oonagh van den Berg 34:34 


Okay, so it is a bit chilly in the winter then. 

Malcolm Wright 34:36 


Yes, it got a bit chilly in the winter. We had snow and deep snow drifts and things like that, which was a surprise the first year I moved there because I thought it was just a holiday. It was it was a fantastic experience. And you know, got the second language along the way. 

Oonagh van den Berg 34:58 


I say my godfather is from Greece. He is from Kalamata. And we spent a lot of our childhood the Peloponnese. The first time I went it must have been around 1984. It was just after the massive earthquake they had had. People were living in Red Cross tents, I remember on the time, all the buildings had collapsed. And if you dropped a coin into one of the cracks in the road, you could never actually hear it drop, because the cracks just were endless. And it was just such a strange experience living somewhere that had just suffered like a natural disaster. Everybody, they were just the happiest and kindest. And that is one thing I love about Greece. Then when I was older, I had a summer job working. I worked as a waitress in a cocktail bar in Calcutta, in Corfu. And then the following year, I got a job as a holiday rep. And yes, all the stuff that you see on the TV is true about holiday reps. But mine was a bit more of a family one, but it was a really great experience. I remember kind of picking people up from the airport, bringing them on the big tour bus, dropping them off where they were supposed to be staying, finding out that somebody else was sleeping in their bedroom. I love Greece, and my parents have a house in Cyprus. So, I did not know that about you. The other thing that I find out about you apparently, you respond to emails very quickly. You have a recommendation back from 2011. Malcolm is very professional and responds quickly to emails. But honestly, Malcolm on behalf of the industry, I want to say a massive thank you to you for the work that you are doing. You are such a motivating force in the industry in terms of pushing forward the right change in in this space, in the regulatory space for cryptocurrency and all other types of related products. What keeps you going? I know you like to run. I know, like me, you sometimes get a trapped nerve in your shoulder. What keeps you going? And what do you do outside of the Malcolm that we see driving the industry? 

Malcolm Wright 37:51 


I think is just actually doing the right thing. There is two parts to it. One is doing the right thing. And the second one is helping others to really become the best that they can be. So, that can manifest in several ways. And whether it is through GDF, or through mentoring or other opportunities. I just think that those two things really sort of keep the energy levels high. I also really like just the variety of what I do. The different facets of it, I think I am not somebody who likes to do one thing and just one thing. So, the different variety and pinging from one thing to the next. Although it can be quite tiring, sometimes gives me energy, which is a bit weird. So, I like running and hiking those kinds of things. Not more long-distance hiking rather short one or 2k then I might do a little bit longer. The more challenging, the better. 

Oonagh van den Berg 39:01 


My husband's boss he does these ultra-marathons. Three marathons in three days or something like that. 

Malcolm Wright 39:14 


Oh, wow. 

Oonagh van den Berg 39:16 


It is insanity. They are hiking for 52 hours nonstop. Running for 52 hours nonstop. I could not think of anything worse! I ran a marathon once because somebody said to me, I could not do it. And I am one of these people. Do not throw down a gauntlet in front of me because I will pick it up. And so, one of my friends said you would never be able to run a marathon. I was just like, okay, challenge accepted. I did do London Marathon. It took me five hours and I couldn't walk properly for days afterwards. But I am so glad did and that I actually did achieve it. But two days later, I actually got a place in the New York Marathon. And I very quickly declined. But it's a great way to see the city, if you ever want to see the city and in a short period of time, just do a marathon. 

Malcolm Wright 40:17 


           I guess you get to see more of it towards the end as you get tired! 

Oonagh van den Berg 40:21 


Because the thing is, you are not running and you are not walking, your kind of doing the speed walking thing in between. And obviously, with my name and I had my name on my top and people were shouting, ‘Come on Ognag’. I was responding to anything by the end. I managed to get through. But I have never been so excited to see Buckingham Palace in my life. But one of the things I love that you mentioned is about variety of that is what I love about working in compliance, no two days are the same. You can write a to-do list for tomorrow and if you get one thing on that list completed, that's a great day. I just love the fact that every situation is niche to itself. And there's similarities, but you always must look at things through a different lens. I don't think that there's any job out there that in my perspective, that is as rewarding as the work that we do. I genuinely believe that we make a change. When we get our jobs right, especially in the fields of anti-money laundering, we actually do save lives, we stop or we at least intercept money's involved in human trafficking, in illegal organs, all of these types of things. And so, Malcolm on behalf of the industry I want to say a massive thank you to you for everything that you're doing in the crypto space. You are one of the global leaders in this area. And it's been such a pleasure and a privilege for us to even borrow an hour of your time today just to chat with you. 

Malcolm Wright 42:07 


Thank you and keep doing what you are doing as well. I think the work you have been doing on RAW Compliance, and the posts and the master classes. We see so many people now, liking or sharing the posts is it is amazing. It is amazing progress. Given it is still such a young initiative. 


Oonagh van den Berg 42:26 


Yes, thank you, sometimes I do wonder if other people are as interested as I! 

Malcolm Wright 42:34 


It is all going to play out so much over the next year or so, particularly as the world starts to turn again. Because things will be different, the way that the financial crime can be detected will be different. The way that you do onboarding will be different. So the timeliness of saying; ‘Well, actually there needs to be an approach to training and helping upskill those people that work in compliance. Because all the people working in compliance already have the right skills, they just need to be uplifted into a new way of thinking, a new way of augmenting those skills with some other things that will make them ready for that next step and that next leap into what this new world is going to look like. 

Oonagh van den Berg 43:27 


You mentioned it earlier as well about the importance of mentoring. I really believe that as an industry, if we want to drive innovation, we have to be sharing knowledge and having the real discussions that we need to have about the challenges we're facing. And that is, why we built the RAW platform. We are trying to bring people together. And we did implement a mentor mentee program, which has over 100 people now on board, because we just saw that there was not initiative like this happening globally. The responses have been amazing. On the difficult days when there is a lot of stuff going on. That is what keeps us going. The fact that there are these nice positive messages come through from people saying that you do make a difference. I am really appreciating the help that you are giving us. So again, Malcolm, thank you so much for joining us today. And I hope later today, we are going to be releasing our first part of our 101 series. So, we've decided to release a set of like three- or four-minute videos of compliance topics like what is AML or what is market abuse. And we decided to do something different. And we have had the voiceovers done by some voiceover artists. So today, it is what is AML hosted by David Attenborough. AML and compliance training in general, it is serious, but we need to shake it up and blow off the cobwebs. So, we are trying to just make it a little bit fun and do something different. So, I hope you enjoy it. And, if there's anything additional that we can do to support the industry, just let us know. We're open to all ideas because we just want to help and that's what this platform has been set up for. 

Malcolm Wright 45:30 


For sure. Thank you. 

Oonagh van den Berg 45:32 


Thank you, Malcolm. Have a wonderful evening. 

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