We all know that compliance exists at TransferWise, but in the recent weeks as we read and heard about various compliance issues affecting other financial institutions, it got us thinking – what if it was TransferWise in the news, would you have faith in our compliance programme? How well do you know what the compliance team does at TransferWise? This blog is the first of many, we hope to re-introduce the compliance family, showcase how we contribute to the mission, tell you about all the cool, innovative stuff we are building and eventually make you as confident as we are in our compliance programme. For today, we look at who we are and what we do. So,make yourself a brew, and comply with me.
The compliance family at TransferWise is big; in-fact we are one of the largest teams within TransferWise. The team consists of more than 300 great Wisers who take care of our AML, Verification, Fraud and Enhanced Customer Due Diligence (EDD). The teams Responsibilities are split and cover everything from the verification of our customers, to ongoing monitoring, including customer refresh cycle (where we ensure customer information is up-to date), transaction monitoring, sanctions, suspicious reporting, as well as staying on top of existing and upcoming laws and regulations that impact our customers, our systems and the controls we have in place.
The compliance mission is to build, maintain and defend a robust compliance program that protects our customers and TransferWise from threats of financial crime and helps us remain compliant with our regulatory obligations. We do this by:
- Verification: We ensure that we know our customers by conducting appropriate Customer Due Diligence (CDD) or Enhanced Due Diligence (EDD) and we ensure that existing customers information is kept up to date
- Monitoring: We monitor our customers throughout the account life-cycle to make sure that accounts are being used for the intended purpose. To achieve this we have transaction monitoring, sanction screening, special investigations and Acceptable Use policy
- Loss Prevention: We prevent financial loss to the company, our customers and other innocent victims. To do this, the Fraud team scans every transaction for potential fraudulent signs, investigates potential fraud matches and deals with chargebacks
- Licence Maintenance: The compliance team maintains all of our licences. This involves convincing regulators of our ability to continually meet regulatory obligations (with help from other teams)
- External Reporting and law enforcement liaison: Sometimes, bad people slip through the net. When we catch them, we have an obligation to report them to the competent authority and liaise with local law enforcement to either provide further information or freeze the funds
- Partner Obligations: Not only do we have an obligation to law enforcement, but we must also ensure we comply with the requirements set forth by our banking partners. Poor relationships may impact our ability to provide products to our customers.
- Audits and Exams: We know we run a tight ship, but most external parties won’t just take our word for it. We therefore showcase our program to external auditors and sometimes to regulators, and get a nice report at the end of it, with helpful recommendations of what we can do better.
But that’s not all we do. We are also:
- Innovative – Did you know we utilise machine learning to help us prevent, detect and deter the bad guys? Machine learning is applied artificial intelligence. We use the data we have gathered in the course of catching the bad guys to help automatically detect and deter similar patterns or behaviours that pop up again.
- Pro-active – We pro-actively try to engage with relevant external parties such as regulators, law enforcement and industry bodies. For example, we engage with law enforcement because we want to help them understand typologies of financial crime, with regulators we engage because we need them to see the impact of certain obligations on our customers and on TransferWise, but also show them that the innovative solutions that we use are efficient, and we like to engage with the rest of the industry because you can always learn something new.
- Open – We believe in TransferWise, and we believe in our compliance programme. We take every opportunity to showcase our programme. This means attending conferences as speakers or presenting in industry meetups. We are always happy to attend external and internal meetings where we get the opportunity to showcase and build confidence in the compliance programme.
- Team Players – Most teams within TransferWise will need compliance input or support at one point or another. Sometimes launching a new product will mean compliance has to adjust some of the controls and be confident that we are not carrying any extra risk that cannot be mitigated. We are always happy to engage. Just let us know early on in the process.
According to our own internal measurements, external assurance reports and regulator confidence, yes it is. However, we are acutely aware that criminals are constantly looking for ways to be one step ahead. We try and anticipate new typologies and also continuously monitor the efficiency of our controls.
We keep on top of the changing regulatory landscape and try to come up with systems and controls that help us remain compliant with the least effect on our good customers. Sometimes, this is not always possible, and the customers may suffer an inconvenience as a result. Be assured that there is a great team of hardworking people trying to solve the inconveniences, but that this takes time and it will never be at the expense of TransferWise remaining compliant and TransferWise will never take unnecessary risks.
How can you find out more about Compliance at TransferWise?
- Keep up with our blog posts!
- If you want to know what open positions we have, see all our compliance roles here.
Fascinated? Look out for our next blog, we will tell you how we have used our innovative tools to catch the bad guys, the types of bad guys we come across and what we do as a result!
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