With two decades of experience in bank fraud investigations and anti-money laundering compliance—including the creation of early-warning systems to detect potential money laundering and suspicious activity—Thomas Bock was recruited by K2 Integrity in 2012 to lead the firm’s Financial Crimes Risk and Compliance Practice. His career is dedicated to thwarting criminals and global terrorists by assisting financial institutions in disrupting their access to illicit funds. Never far from mind is his memory of the horrors of a September day in 2001, when the world changed and his professional expertise became more necessary than ever.
What first drew you to your profession?
Quite simply, my father. I would listen to the stories he would tell me about his job. Charles Bock led the Fraud Prevention and Investigation team at JP Morgan Chase for many years and was considered an industry expert in bank fraud. Our weekly conversations at the dinner table left no doubt in my mind about the career I wanted to pursue.
What are the most serious problems that banks face today? How do you help address them?
The challenge, day in and day out, is the prevention and detection of money laundering and/or terrorist financing—and ensuring regulators that a control environment is in alignment with the bank’s enterprise-wide risk. Our clients face scrutiny by regulators every day. We assist them in designing and implementing a robust compliance foundation that is sustainable and meets the regulatory requirements of the USA PATRIOT Act.
Such as potential for another 9/11, when al-Qaeda terrorists hijacked passenger planes to fly suicide bombing missions against the World Trade Center in New York and the Pentagon in Washington in September 2001?
On the morning of September 11, I sat with colleagues around a small TV at the offices of a big four accounting firm, where I was working on forensic investigations at the time. The television broadcast mentioned names of hijackers—names we recognized because they were focal entities in an investigation we’d done on behalf of one of our banking clients. Sixty minutes later, we were in that bank client’s offices with the F.B.I. going over the money flow of transaction activity.
It became clear to me then that the work we perform every day—our firm’s work as well as our clients’—is very important in the fight against global terrorism. It’s paramount that banks put procedures in place to detect money laundering. They’re the front lines in this fight.
In dollar terms, what are you up against in this fight?
Imagine $4 trillion just in New York City—$4 trillion a day—going into financial systems worldwide.
Does the modern convenience of cyber fraud via home-based computers make tracking dirty money more difficult?
Yes. It is like trying to find a needle in a haystack. You no longer have to walk into a bank to commit fraud; you can do it from your home.
What sort of educational and professional background has prepared you for the difficult work you do now at K2 Integrity?
I hold a bachelor’s degree in finance and computer information systems, and a master’s degree in economic crime management. I began my career at Republic National Bank in corporate security, working on fraud investigations and prevention systems. I was a consultant at a Fortune 500 financial institution, where I managed a team that designed and implemented a global transaction monitoring system—to assess client risk and sanctions liability, as well as tracking suspected money laundering and terrorist-financed operations.
I was also executive director at Daylight Forensic & Advisory LLC, responsible for business and product development and client service activities. I spent nine years at KPMG leading anti-money laundering initiatives for multinational financial institutions. Also at KPMG, I developed and implemented an anti-money laundering transaction monitoring and case management system to help global financial institutions comply with suspicious activity reporting laws in accordance with the Bank Secrecy Act.
When you suspect fraudulent bank activity, how do you pursue the fraudster?
You have to understand the economic purpose and money flow of the transactions, and you have to get into the mind of a criminal. What’s the easiest, fastest way to move money around the world—and conceal it? I know many ways. It’s similar to a law enforcement agent who goes deep undercover. You have to know how a criminal behaves and know how to investigate and perform deep due diligence.
In times of need, criminals will find ways to survive; in times of growth, criminals get greedy. So my job is always interesting.
How did you arrive at K2 Integrity back in 2012?
I came with a business plan. I had a focus, and a leadership at K2 Integrity that gave me a blank canvas and support. We began with one man—me—and we’re now close to 60 full-time people executing on solutions to complex compliance problems for our clients.
And the size of your client list?
I didn’t set out to build this practice with hundreds of clients, I set out to find the right clients and keep them for a long time—based on our providing value, and a relationship built on the ability to execute and on trust and confidence. I don’t want to be the consultant who comes in one time and helps fix the problem and then you never see them again. I want to be considered the advisor of choice in many different areas.
I’m happy to say that when you look at our client roster, every single one has given us multiple assignments. That is a tribute to the team we have assembled at K2 Integrity.
What can a potential bank client expect from an initial meeting with you?
First, I listen. Consultants think they have to speak much more than listen. That’s trouble. So when I’m called in—60 percent of the time because regulators tell the bank it has to do a better job—I listen to their concerns: what keeps them up at night, how their business operates, their view of risks. Then I can talk from experience.
What’s in the future for your practice area?
We’re doing more and more in nontraditional payment systems, like Bitcoin. The world is changing. There’s a lot of uncertainty, but we’re in the forefront and our clients will be prepared.
You have to stay current with trends. You have to understand where the laws are going—the proposals, the legislation. You have to speak with regulators over coffee, and understand where the next trouble point or concern is.
You will not survive in this business if you’re not current. The world moves quickly. If we’re not quicker, we’re not going to be successful.
What does your father think of your career so far?
Not to get sentimental, but I think he’s extremely proud. He’s retired now. He was very well respected in this field. He actually sat with several Presidents and teams to teach them about terrorist financing and how to trace the money flow. I’ve always said to him, “If I can accomplish half what you’ve done in my professional career, I’ll have a pretty good career.”
(The preceding interview with Thomas Bock was conducted by Thomas Adcock, a New York–based independent journalist.)