I was hoping it would be déjà vu all over, again. As a recruiter that focuses on AML, compliance, fraud, regulatory compliance, risk, and legal roles, I had a surprisingly great four years during President Trump’s first administration when it comes to compliance recruitment. Between 2017 and 2021, there were three areas within the regulatory umbrella in the financial services industry that boomed:
- Fraud (prevention, remediation, and analytics). Fraud usually increases during administrations that focus on deregulation. It’s almost a natural economic phenomenon. During administrations that focus on deregulation and are pro-business, there are, usually, a higher volume of transactions, more money in the economy flowing back and forth, and more platforms on which to make those transactions. Fraudsters run rampant in the e-commerce, payments and cypto space, for example, when there is more opportunity to do so. I was placing fraud experts left and right during Trump I (I will refer to President Trump’s first administration as Trump I).
- OFAC/Sanctions. We all want to believe that America’s might come from its superior military and intelligence apparatus. America’s real power is the US dollar. Everyone wants USD. If you really want to non-violently hurt another powerful country and powerful people, you sanction them. President Trump was sanctioning everyone and their mother in his first administration: Syria, Russia, NK, and a myriad of people whose names I couldn’t pronounce. OFAC and sanctions professionals were in high demand between 2017 and 2021.
- AML and Financial Crimes Compliance. I have learned from recruiting during the last two republican and last two democratic administrations that fighting money laundering, countering terrorist financing and following the money is an apolitical issue. There is no US president that is going to say, “please launder your money through our banking system.” It just won’t happen.
What didn’t boom during Trump I was the number of compliance-oriented enforcement actions against the financial services industry. Regulatory compliance took a major hit. For example, in 2016, there were 198 enforcement actions by federal regulators. By 2020, the last year of Trump I, there were 105 (a 47% reduction).[1]
Additionally, the CFPB almost lost its mandate and only came out the other side by the skin of its teeth.
After the election in November 2024, I started planning and preparing for what was to come during Trump II (Trump’s second administration). I thought I had the secret sauce because I did well during Trump I. I am realizing now that history doesn’t always repeat itself. Or, maybe, to put it more quaintly: things used to be so much simpler. Here are my predictions for what will be hot and cold in compliance recruitment during Trump II. Let’s go back to the skillsets most in demand during Trump I.
- Fraud. Deregulation, more money in the markets, and lax enforcement usually lead to fraudsters being more prolific. I am not referring to the next Bernie Madoff or Raj Rajaratnam. I am referring to the “conventional” fraud that takes place on any platform that connects a buyer and a seller or internal fraud by employees. Companies of all types are going to see a spike in fraud and will have to remediate many issues. Fraud prevention and detection are going to be priority and will require, as a combined force, AI, technology and human capital.
- OFAC/Sanctions. From a global political standpoint, I don’t believe Trump will use OFAC as much as he did during his first term. Current names and entities on the SDN might stay the same, but there might not be large net growth to the list considering his current amicable relationship with Vladimir Putin. Syria’s former dictatorship recently fell apart. When’s the last time you heard anything about North Korea? Iran seems to be his only sanctions target now. Although OFAC is the US’s most powerful weapon, I don’t see him wielding it as much as he did during Trump I, which might mean less demand for OFAC professionals.
- AML and Financial Crimes. I stand by my statement before that fighting financial crime is an apolitical goal shared by everyone. However, the federal layoffs that set the early theme of Trump II, might mean there is a lack of human capital available to conduct the examinations that lead to enforcement actions. In addition, the White House said that it will have to approve all new potential regulations from federal agencies.[2] This will affect enforcement actions and government intervention that leads to more jobs.
Here are the areas where I expect an increase in demand for compliance and regulatory professionals, not only because of a lack of potential enforcement (ironically), but also because companies’ survival and growth are at stake:
- Cybersecurity. The demand for cyber talent – both regulatory and technical – will increase exponentially in the coming years (doesn’t matter who is in the Oval Office). Data and security breaches seem to be so common nowadays. You can only imagine how many hacks are stopped daily.
- Data Science and Analytics. Metrics, metrics, metrics. I love math because it doesn’t lie. The most successful companies base their decision on science and analysis.
- AI/Machine Learning. There’s going to be an uptick in demand for compliance professionals at AI companies playing within the financial services industry. AI regulation is still nascent, but AI finance companies are going to boom during Trump II, and they will be required to have an AML/BSA program and/or a regulatory compliance program.
- Export Control. Tariffs on imports will lead to a higher demand for compliance professionals that can enforce those tariffs and make sure foreign countries aren’t obviating them.
- Blockchain and Tracing. I see the biggest growth in demand for compliance talent in the crypto, DeFi and Web3 areas of financial services. Alternative finance is going to see a renaissance in the coming years, and there will be an increased demand for expertise in tracing illicit financing on blockchains, in general.
Unless there is a major recession, which is possible, the financial services industry –from your basic community bank to the largest crypto exchanges – is going to boom. The US is going to see an influx of foreign fintechs and financial institutions entering the market. I am already seeing this firsthand. Canadian, Argentine, and Middle Eastern fintechs, regtechs, services providers, technology providers and payments companies have been reaching out to me directly asking for help building compliance programs and teams. They have also asked for my help with sourcing sales and product evangelists who have experience selling compliance and financial crimes prevention tools. It’s hard to say, but I am hoping that an increase in the number of new companies and companies going through additional investment rounds will counter the potential decline in compliance recruitment needs because of deregulation and a lighter touch from the regulators. I truly don’t believe that it is well wishing. At this moment, my company and I are busier than ever trying to fill all types of compliance and fraud roles at traditional financial services institutions, fintechs, and management consulting firms. But it’s hard to read the Trump II tea leaves. We are hoping for the best and preparing for – not the worst – but the unexpected when it comes to compliance recruitment.
[1] chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://guidehouse.com/-/media/www/site/insights/financial-services/2021/fs_q32020enforcementactionstrackerfinal.pdf?utm_source=chatgpt.com
[2] https://www.barrons.com/advisor/articles/weeks-best-sec-trump-executive-order-c1f6c6c8?mod=barronsgooglenews