Meet an ICA Member: Sarah Troy

Sarah Troy, FICA
MLRO and Compliance Officer, Collas Crill

Due to the increasing number of people looking to move careers or begin a career in compliance, anti-money laundering and financial crime prevention, we’ve invited some of our members to share their experiences to help our students, practitioners and other like-minded professionals understand the journey and direction they could take throughout their career.

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Q: How long have you worked in compliance for? What has changed since you first started to now?

I have worked in the offshore legal industry for 13 years, 11 years of which have been spent in compliance related roles, from administration positions, to team management, to Key Person roles such as MLRO/MLCO. I am also a Fellow of the ICA.
Currently, I act as MLRO and Compliance Officer for the Jersey office of Collas Crill, an offshore law firm with offices in BVI, Cayman, Guernsey, Hong Kong, Jersey, London and Singapore.

"Having worked within risk & compliance for over a decade, the function has experienced a great shift in dynamics, from what was once a culture driven by rules, perceived as a tick box exercise if you may-which has now transformed, positively, into a framework based upon principles."

The development and understanding of the risk based approach for example, allows a firm more flexibility when it comes to the creation and implementation of their internal AML/CFT framework. Identifying the key risks within the business, and for each new engagement, allows for resource to be applied more effectively and proportionately. Ultimately, therefore, allowing for mitigating measures that are reasonably commensurate to the risks identified. This emphasizes the change from a role that was once considered greatly process-driven to a much smarter working approach, driven by the outcomes we want to achieve.
The progression of technology in this area, and the explosion in data solutions, allows for continuous process improvement and better management information than ever before. Analytical thinking can be applied, providing us with greater accuracy in identifying where true sectoral, jurisdictional, and business specific vulnerabilities lie, and in being able to use statistical evidence to support the development of effective policies and procedures.


Q: How did you land your first role; was it chance or a calling?

I joined my first employer, a top tier offshore law firm, in 2006, aged 18. At that point, I had not made my mind up on the career path I wanted to head down, but I was sure that I needed to get my foot in the door of a reputable firm, and seek the opportunity to develop myself professionally with their support.
I took the first role offered to me, based in Office Services/Facilities, and being part of a business support function, enjoyed interacting with all levels of employees in a wide array of practice areas and business groups. I was soon promoted to team leader, and found the development of best practice, and providing efficient service delivery very rewarding. Soon after, I was approached by the manager of the firm's client due diligence team, who was looking for a junior administrator, mostly to undertake KYC file reviews.

"With CDD (and the risk and compliance function generally) a new concept to me, I undertook a bit of research, and reviewed the opportunities available to study with the ICA, and with that I knew it was the role for me and one that could take me down many different paths."

With a detective sergeant as a father, and his position in the local FIU, I was naturally drawn to the role and viewed him as a perfect role model and mentor in all things related to financial crime. It was definitely a calling!
I stepped into the role in 2008, completing ICA's Advanced Certificate in Financial Crime Prevention with Compliance a year later. In 2011, I then completed the Diploma in AML.
One thing I had always wanted to do however, was obtain a degree, and when the ICA, in conjunction with the University of Manchester, launched the BSc (Hons) in Management with Compliance, I threw myself at the opportunity to sign up, studying in my spare time and subsequently graduating in September 2013.


Q: What do you find enjoyable about your role? What are the challenges?

The biggest challenge faced in Jersey, as an offshore jurisdiction, is to ensure we maintain our high reputation in line with international regulatory and AML/CFT standards. The offshore financial industry is under constant scrutiny and being part of the solution that ensures good governance, and effective systems and controls, and knowing that my role helps to mitigate the threats of those that might abuse our professional services, is greatly satisfying.

"Whilst it is a challenge to keep abreast of constant regulatory change, it keeps those in this role on our toes, and always thinking about the bigger picture. It motivates, and constantly helps to improve operational efficiency."

One of the most rewarding parts of the role is successfully engendering a positive compliance culture, and when employees seek you for advice and guidance rather than perceiving you with the old adage of "business prevention officers", you know you are doing it right.


Q: What attributes do you think are important for a career in compliance?

An open door culture is an absolute requirement. Staff should be able to access compliance at any time and feel comfortable in doing so and be able to discuss any issues they have. A friendly positive attitude and good people skills are a must.

"Given the raft of ever-changing international standards and regulations and the fact we are all human, there is no doubt that mistakes will be made – nobody is perfect!"

It is important for those in compliance to accept that we all make mistakes, and that in most cases they are not made with intent. It is most important to identify the cause, manage the risk, and ultimately learn from those mistakes in order to mitigate any future risks of a similar nature from occurring.
A good compliance officer needs to be a supporter of change and continual development of a business, its systems and controls. Maintaining an active relationship with employees and having continual communication ensures staff have a greater awareness of compliance related issues and builds upon the positive relationship between compliance and the rest of the firm.
Always act with utmost integrity and you'll be sure to have a rewarding career in compliance.


Meet other ICA members here:

Dilani Sooriyaarachchi, Head of Compliance at Seylan Bank PLC

Adam Rogerson FICA, Compliance Manager

Clare Walker FICA, Compliance Quality Manager

Cyril Esterhuysen FICA, Money Laundering Reporting Officer

Guy Hardill, Int.Dip(Comp); Int.Dip (FinCrime); FICA, Compliance Associate

Kensley McDowall FICA, Managing Director

Louis Parris FICA, Financial Consultant

Kevin Parkinson FICA, Director of Advisory Services

Want to get involved in our 'Meet a Member' campaign?

We’d love to feature you in our ICA Insight series, and in inCOMPLIANCE®! Getting involved is a fantastic way to raise your profile within the ICA and an opportunity to interact with your fellow members, as well as those interested in entering the field.

Find out more and let us know you are interested by emailing