CEO Insights Magazine

Compliance has been a critical aspect of trade finance solutions, and the role of Chief Compliance Officers (CCOs) has be­come paramount in ensuring the integri­ty and security of trade finance. CCOs are tasked with implementing and monitoring compliance policies and procedures to mitigate the risk of financial crimes such as money laundering, ter­rorist financing, fraud, and corruption. One such CCO who has cultivated a remarkable talent for identifying critical details and offering effective solutions is Bhupinder Singh. With over 17 years of experience, and notable certifications such as a Certified Anti Money Laundering Special­ist (CAMS) and an ICA Advanced Certification in AML/CFT, Singh's passion for compliance, dedica­tion to his team, and drive for innovation make him a sought-after expert in the field.

CEO Insights Asia recently had the opportuni­ty to interview Bhupinder Singh, Head of Compli­ance at Commerz Trade Services, to gain insights into his professional background, leadership ap­proach, and the challenges faced in the compli­ance domain.

How has your professional journey been so far, and what motivates you to do more?

The fact that I can contribute my very best in help­ing society and the world become a safer place has been the highlight of my 17 years long pro­fessional journey. After completing my Bachelor’s Degree in Business Administration, I ventured into the banking industry. I started in a contact center with a local bank and gradually moved into a shared services environment with a global bank. In 2013, I transitioned into the Compliance field, focusing on Transaction Monitoring. Over the years, I have gained experience in various compliance roles, including Sanctions Screening, KYC, Trade Based Money Laundering, and Anti- Bribery & Corruption. What motivates me is the continuous learning aspect of Financial Crime Compliance. Despite the impossibility of elimi­nating financial crime, I believe that my contribu­tions can help create a safer society. In addition, I aim to change the perception of compliance from a show-stopper to a business enabler, striking a balance between compliance requirements and supporting new business initiatives.

How is Commerz Trade Services as an organization and its current position in the market?

Commerz Trade Services was established in 2012 and is a 100 percent subsidiary of Commerzbank AG based in Frankfurt, Germany. The company has grown significantly, initially focused on Trade Fi­nance, specifically Export Letters of Credit (LC). Our vision is to become the most innovative low-cost service provider for standardized and tailor-made solutions in the banking sector. Today, we provide services for Trade Finance and handle Transaction Monitoring, Client Verification, Market Operation, Loan Administration, User Account Administration, and other IT support functions for the bank. We are expanding our operations and will soon open an of­fice in Penang, Malaysia. The company’s growth and the opportunities it offers make it an exciting organ­ization to be a part of.

What methodology do you follow to deal with any general compliance risk of financial crime?

We follow a risk-based approach when dealing with compliance risks. Suspicious transactions or escalated alerts, such as sanctions-related issues, are assessed based on various factors. Individ­ual hits are evaluated by considering matching names, date of birth, and nationality. In the case of company hits, factors such as country of regis­tration and company registration number are ex­amined. For anti-money laundering (AML) alerts in trade finance, we scrutinize the business na­ture of the involved parties, pricing fairness, and vessel movements. It is important to have a com­prehensive risk assessment tailored to different scenarios.

Could you reflect on some of the toughest challenges you have encountered in your journey so far? How did you overcome them, and what did you learn?

One of the toughest challenges I've faced is cul­tivating a compliance culture throughout the or­ganization and  establishing the foundation for ethical behavior at all levels. Changing mindsets and ingrained beliefs takes time. To address this, we adopted a top-down approach, clearly commu­nicating that the company does not tolerate un­ ethical behavior. Straightforward and concise pol­icies and procedures, easily accessible through a code of conduct, were consistently communicated. Regular email communications and verbal discus­sions about expectations became a priority. Train­ing initiatives played a crucial role in engaging employees and sending a clear message. We are also working on implementing a Speak Up pro­gram to encourage employees to report violations without fear of retaliation. These experiences have made me a better Compliance Officer, help­ing me manage senior management and employee expectations while creating win-win situations.

You mentioned enabling compliance as a business enabler, and for that to happen, it is essential to train your team to align with the same ideology. How do you ensure that?

We have an annual training plan, where topics for the year are determined in advance. New employ­ees receive a comprehensive introduction to com­pliance risks, policies, and procedures. I conduct compliance training for all 300 staff members every quarter using platforms like MS Teams. Regarding team management, I prioritize direct communication, delegation, and leading by exam­ple to foster a positive and productive work envi­ronment. Transparency and clear communication are vital in achieving our shared objectives. Trust is critical in empowering team members; when tasks are assigned, I trust individuals, allowing them to grow and thrive. Witnessing team mem­bers reach their full potential and succeed in top positions brings me a sense of pride and fulfill­ment.

Bhupinder Singh, Head of Local Compliance, Commerz Trade Services

Bhupinder, the Head of Compliance for Commerz Trade Services, brings a wealth of expertise and qualifications to his role. With a Bachelor's Degree in Business Administration and certifications as a Certified Anti Money Laundering Specialist (CAMS) and an ICA Advanced Certification in AML/CFT, he possesses a keen eye for detail and a natural talent for finding solutions. With 17 years of professional experience, Bhupinder oversees the management of compliance risks and ensures the effective implementation of all AML/Sanctions programs within the company.