CCO Spotlight Deborah Marcus

CCO Spotlight: Deborah Marcus, Moelis & Company

For this installment of our CCO Spotlight series, ComplySci’s CEO, Amy Kadomatsu, interviewed Deborah Marcus, Head of Compliance, Americas, at Moelis & Company, a leading global independent investment bank that provides innovative, unconflicted strategic advice to a diverse client base from 22 geographic locations in the Americas, Europe, the Middle East, Asia, and Australia.

Can you tell us a little bit about Moelis and how the firm has grown over the years?

Deborah: I was fortunate to join Moelis in 2008, which was an interesting time to join any financial firm. I had come from JPMorgan, just following the Bear Stearns merger and had been working there during prior few mergers, as well. While at JPMorgan, one of my central responsibilities was the development and administration of Compliance policies and procedures for the investment bank. Joining a new entity like Moelis was exciting.

Moelis started in the US with offices in New York, Los Angeles, and Boston, and has since grown throughout the world. Our clients have really come to view Moelis as a trusted corporate advisor thanks to the leadership and example of Ken Moelis and the Firm’s other founders.

Can you talk a little bit about your journey to Compliance?

Deborah: I laugh a bit when I think about Compliance in the early days. It was something that lawyers and accountants might do, but it wasn’t really a profession. Not long ago I attended an event at Fordham Law and was surprised to learn there’s an entire division now focused on Compliance and Regulatory Law.

I was introduced to Compliance when I was looking for an internal legal role out of Milbank, where I had been an associate in their corporate finance practice. I made the decision to go in-house and Compliance was one of the areas in which they were looking for new talent.

Legal and Compliance at JPMorgan were one department at the time I joined, and I learned on the job. I helped each of the different departments in the investment bank write their policies and procedures, and offered advice to compliance officers, and that was really the beginning of my Compliance career.

When people are coming to you for career advice, what would you tell them?

Deborah: I think that it’s important to find a corporate culture that respects Compliance as an independent voice. Compliance is still up and coming to some extent. There are many companies that have matured and understand the value of a strong Compliance voice. For someone evaluating a job opportunity, it’s important to consider whether Compliance will receive the respect and ear from management that it needs in order to be effective.

I’d also advise a young person coming into Compliance to consider a regulatory role. A role with a regulator can provide insight across a variety of firms.

Any other career advice worth mentioning?

Deborah: One of the Compliance requirements that you don’t often read in a job description is being able to nudge. 99% of the time people aren’t responding out of any malice or carelessness about the rules. They’re just busy. They don’t notice something has fallen to the bottom of the list. Being politely persistent can make a world of difference, and often, if you do it the first time, the second time they’ll remember more quickly.

“It’s important to find a corporate culture that respects Compliance as an independent voice.”

How do you identify that skill when building a team?

Deborah: I often give potential hires a scenario: What do you do if someone’s not really responsive? Would you feel comfortable nudging? I’ve had people that ultimately say they don’t feel comfortable calling six times, or don’t feel comfortable emailing several follow-ups. It’s a great reminder that personality of a potential candidate is important in a Compliance role.

What are some ways you stay on top of the latest trends to ensure that you aren’t falling behind in your career?

Deborah: I think there’s so much valuable information right now coming directly from the regulators. FINRA has webinars and publishes a lot of useful information on their web site now. The SEC recently had a roundtable on regulation, and it was live and lasted for a few hours. There’s plenty of good material coming from the regulators.

I would also point to the value of peer-to-peer networks and sharing of information, whether it’s formally through some sort of webinar, or just informally picking up the phone and asking a colleague what’s new and what they’re spending their time on. This helps ensure you’re not missing anything.

We’re currently having this conversation on a Zoom call in the middle of a pandemic. When you think about these past months, has the pandemic changed how you approach Compliance at all?  

Deborah: Sometimes the smaller conversations get lost when we’re not in the office and able to run into each other. Picking up the phone becomes more impactful than sending an email and now it’s more important than ever since you’re not running into people and having that face-to-face interaction.

At Moelis, we’ve always invested time, energy, and money into an in-person training program, and now we’re replicating that in a virtual setting so that whenever a new hire joins, the compliance message comes through strongly. 

In our training, we’ve definitely made changes to our discussion to ensure that we’re comfortable with workers’ personal environments. It’s critical that employees have an appropriate place to work and the appropriate materials and technology to help maintain confidentiality.

Are there any new innovations within the industry that you’re excited about right now?

Deborah: The exploration of artificial intelligence is extremely exciting for surveillance in particular. I think it will lead to us being more efficient and more targeted.

We’ve been home growing a few tools and looking for effective ways to apply the technology. We’ve been looking to our IT Departments for some of the security technologies they use and ways to leverage those in the surveillance environments so that we are learning more about behaviors. It’s about relationships. Are you talking to the right people? Are you saying appropriate things to those people? Do you have the proper access to information? Perhaps these holistic questions about a person’s individual behavior will become more apparent when we implement AI to conduct surveillance.

Every time I talk to CCOs, it’s always this balance of managing people who aren’t reporting to you in an organization while also managing data and technology. How do you do it?

Deborah: We have always valued building relationships and helping employees understand that Compliance isn’t there to hinder their work, but really to help it happen in an appropriate way, and to demonstrate what can go wrong when rules aren’t being followed.

When it comes to data, I think we in Compliance know what we were looking for, but sometimes within the systems that we have available, don’t know where to look. At Moelis we’ve hired a Compliance Analyst who can use these systems to help us achieve our goals. While he sits in our department, he’s conversing with IT all the time and using their systems.

Before that, I would be incessantly asking IT questions: Can you tell me this? Can you find me that? Can you give me a report on this?

“We have always valued building relationships and helping employees understand that Compliance isn’t there to hinder their work, but really to help it happen in an appropriate way, and to demonstrate what can go wrong when rules aren’t being followed.”

I always like to ask a fun question. What is your guilty pleasure?

Deborah: I love to disappear for a whole day and just read a book. Maybe drink a cup of coffee, or if I’m really honest, have some ice cream with the book!

Sounds delicious. Thanks so much again for your time. I really appreciate it.  

Editorial Note: At ComplySci, we understand the tremendous value compliance professionals can gain from networking and learning directly from their peers. For the CCO Spotlight blog series, we are sitting down for candid conversations with Chief Compliance Officers from some of the firms we work with. This blog series will share those CCOs’ thoughts, ideas, and best practices for compliance programs with our readers. The views expressed in this blog post are the CCO’s own views and do not necessary reflect the views of their firms.