A Woman’s Contribution to International Compliance

In 2016, a woman in Mexico City faced the possibility of a promotion. She was also pregnant with her second child, and she was concerned that the news of her pregnancy could jeopardize her promotion. She faced a challenge with which many women can empathize: Should she announce her pregnancy with the joy and celebration it deserves or conceal it? She chose the latter.

“Concerned that my pregnancy would jeopardize my promotion, I chose to conceal the news for a couple of months, denying myself the opportunity to publicly embrace a significant blessing in my life.”¹

The woman facing the challenge in 2016 was Elisa de Anda Madrazo. Fast forward to the present and Madrazo is now the head of a collective action to thwart financial crime. With public policy as her instrument of change, Madrazo is fighting financial criminals, terrorism and nuclear proliferation as the current president of the Financial Action Task Force (FATF). Yet, she admits to facing the same conundrum that so many other women have had to face and to giving in to her personal concerns and fears.²

Madrazo explains that while “women in leadership positions are often invited to share success stories to inspire and mentor others,”³ her own self-critical story can also be instructional. “Looking back, I realized that if I had possessed the knowledge and awareness I have today, I would have acted differently. I know now that I could have done better.”⁴ The event shaped her point of view, and she reflects on what she could have done.⁵

Present Day

As president of FATF, the Paris-based multinational intergovernmental organization dedicated to combating money laundering and terrorist financing, Madrazo is a Latina at the forefront of combating financial crime on a global scale. She is only the second woman to lead FATF in its 35-year history. While also serving as the foreign officer for the Mexican Ministry of Treasury, Madrazo has been successful in highlighting the importance of other Ministries of Treasury that are also on the front line of the anti-money laundering (AML) strategies.

In her role as president of FATF, Madrazo is focusing on:

Identifying ultimate beneficial owners in order to identify illicit resources;
Preventing money laundering and terrorism financing using virtual assets; and
Strengthening the capacity of national authorities to freeze and recover assets—a significant issue for developing nations.⁶

She has also modernized financial crime guidance by focusing on risk-based implementation of the current FATF standards. These measures allow the AML and counter-terrorist financing (CTF) measures from a specific country to adapt to the needs, characteristics, local laws and context of that country, ensuring that the implementation is effective and balanced.

Madrazo has also advocated for financial inclusion, believing that granting access to the formal financial system to individuals who would otherwise turn to the underground economy—where wrongdoers can hide their assets—would diminish the use of such systems. As a seasoned public official for the Mexican financial intelligence unit, Madrazo had to deal regularly with human trafficking rings and money laundering from drug-trafficking organizations.

Before earning a Master of Laws degree from Harvard University, Madrazo obtained her law degree in Mexico, a country outside the Group of Seven (G7). Low-capacity countries like those outside of the G7 can face difficulties implementing FATF’s AML/CTF standards, which were designed primarily to be implemented by advanced economies. Madrazo is now the dark horse for change in countries that need these standards the most, yet often are the ones that find them the most difficult to implement.

Diversity in Compliance

It is apparent that women are active in the field of compliance, as we see from the various compliance-related podcasts, articles, conferences, working groups and activities directed at and populated with women. These endeavors foster the exchange of ideas that empower women who are tasked with uncovering fraud, bribery, money laundering and other illegal activities to stand tall in the face of such transgressions.

Now imagine the multiplying effect when these women come from different backgrounds, law regimes and styles of enforcement. If 10 people in a room all have the same background and point of view, the effect of adding someone with a completely different experience, history and frame of cultural reference can transform mindsets, enrich the level of dialogue and foster change.

Conclusion

In an area of rapidly changing politics, where significant regulatory changes are needed and the legal landscape is quickly changing to keep pace with technology, female leaders in compliance are spearheading accountability initiatives around the globe. International women with strong backgrounds from developing nations can indeed turn the tables, for they have already seen these changes in their home jurisdictions.

The many women across the globe working in the compliance field epitomize a cognitive dissonance within the industry, while spearheading change and working tirelessly to steer the compliance world into the future. Madrazo is one such woman.

Martha Mallory, due diligence relationship manager, Dow Jones Risk & Compliance, USA, martha.mallory@dowjones.com