Where You Stand, There Dig Deep; Below You Lies the Well—Why I Work Here (Hitomi Okada)

Hello! My name is Hitomi Okada. I’m the manager of the teams in charge of anti-money laundering and combating the financing of terrorism (AML/CFT) at Merpay and Mercoin. As of March, it’s been three years since I joined Mercari Group, and I thought writing a Why I Work Here article would be a great opportunity to reflect on the past three years and my career so far.

Overcoming the “employment ice age” and making a bold career change

As I wrote in the introduction, I currently lead AML/CFT in Mercari Group’s financial businesses—but to be honest, I never even dreamed of doing this as a career back when I was in my 20s.

I went to university overseas, and then started looking for a job in Japan. At the time, it was the middle of the “employment ice age”—a major job shortage in Japan in the late 1990s and early 2000s. There weren’t any alumni of my university that I could pay a visit to for advice on job hunting, and I didn’t know much about the job market in Japan, so my job search wasn’t going very well. After some time, I finally got a job as a contract employee in the general affairs department of a chemical manufacturer headquartered in the US and started my life as a working adult.

There, I worked as an assistant for the department head and on office-related tasks like the relocation of the company’s head office in Japan. The company was very thorough about complying with laws and regulations, and I’m thankful that I had that concept drilled into me from the very beginning of my career. There was another new graduate of my age who joined a related department as a full-time employee, and I sometimes had mixed feelings watching her get to go through a full new-graduate training program, but my contract ended after about a year and a half when the project I was in charge of finished, so I didn’t have time to feel down—I had to look for a new job.

In my first job, I had gotten a glimpse of the internal workings of a company as part of the general affairs department, so this time, I wanted to deepen my understanding of external work. I also really wanted to find a career position, so I focused on sales positions in my job search.
　
Three months later, I was hired for a temp-to-perm sales position at a company that sold toiletries, which was something I had been interested in. I was promoted to the full-time position I was looking for six months later. At that company, I spent around two and a half years proposing toiletries like deodorant and hair removal products to our existing clients, such as agencies and retail headquarters. I enjoyed my work, and I learned a lot about sales strategies and building relationships with buyers and sales representatives from other companies, but I found it hard to be passionate about my sales because I wasn’t able to hear from the customers that actually bought the products in stores. Around then, I met with a friend who was working as a consultant. After hearing him talk about how he regularly worked to gain expertise and solve and improve problems that their customers faced, I was inspired to leave my job.

The turning point in my career: discovering AML/CFT

After I left my job, I was studying to get finance-related certifications when I was offered a position in support work for a consulting firm that had just been established. The company’s mission to act as a bridge between finance authorities and private companies resonated with me, and I decided to join on the spot. Thinking back on it, that decision was a major turning point for me, because it gave me experience and encounters that would define the rest of my career.

The first such encounter was with AML/CFT, which is now my area of expertise. Around 2008, some time after I started the job, I discovered that financial institutions were required to take measures for exclusion of anti-social forces and AML/CFT. When I was in elementary school, I wanted to be a police officer, but I gave up due to the height requirements at the time. Ever since, I hadn’t had any real dreams, but learning about AML/CFT felt like the fog had finally lifted and I could see the sun again. I decided that this field would be my life’s work and devoted myself to studying it as much as I could.

Another such encounter was with a coworker who had previously worked in the FSA, whose expertise and attitude toward their work gave me a large amount of opportunities to think about how financial regulators should act.

“Inspectors are like X-ray operators—they scan the condition of a financial institution and report it as-is.”
“90% of an inspection is the preparation; only 10% is the actual inspection itself.”
“You can’t focus only on AML/CFT. You have to think about other risks and the overall balance.”

The things I learned and the advice they gave became the foundation for my approach when I later joined the FSA and had a major impact on my actions. In particular, I remember my coworker talking about how he liked a quote from the philosopher Nietzsche: “Where you stand, there dig deep! Below you lies the well!” That quote has become very important to me as well; it reminds me of the importance of looking inward in my daily work and even when looking for a new job.　

Around six years after I joined, as I gained experience and the work I took on gradually became more and more specialized, and I even became more involved in giving advice rather than merely supporting those around me, my coworkers suggested that maybe I would be suited for a career as an inspector. I took that suggestion and applied to become a fixed-term official at the FSA in order to solidify my career.

Accepting the fear and responsibility of a position where one comment can influence the entire industry or local economy

I joined the FSA in 2014, and my first assignment was inspection work for foreign bank branches in Japan. After that, I transferred to work on monitoring planning for global systemically important financial institutions (G-SIFIs), a category that includes major banks, and also took charge of AML/CFT monitoring planning for the foreign bank branches overall.

In summer 2017, I was dispatched to participate in an AML/CFT training program held by the US’s Office of the Comptroller of the Currency for foreign financial supervisors. There, I was able to further deepen my understanding of AML/CFT frameworks through the organized training about AML/CFT and monitoring techniques. After the training was over, I returned home to find myself appointed to a position in charge of monitoring cryptoasset exchange business operators. I applied the knowledge I gained through the training program to my work of screening registrations of cryptoasset exchange business operators and to creating structures for monitoring, after which I focused on inspections and post-inspection follow-up measures.

I was kept busy, and in 2019, I dove into revising the Reference Cases on Suspicious Transactions (a document for financial institutions to reference with examples of transactions suspected of involving money laundering or other fraudulent behavior), responding to advice and guideline revisions from the Financial Action Task Force (FATF; an international organization that sets standards for AML/CFT), and handling the FATF’s mutual evaluation of Japan. In my final year at the FSA, I was involved in monitoring for funds transfer business operators and regional financial institutions.

If anyone were to ask me what I thought the most worthwhile job was, to this day I would answer financial administration without any hesitation. One offhand comment can influence the lives of individual workers at financial institutions, the future of financial institutions, and even the industry as a whole or the local economy. It can be scary, but being able to accept that responsibility, proudly and sincerely carry out your work, and work with overseas authorities while being deeply involved in shaping AML/CFT in your own country is a dynamic role that I find extremely fascinating.

What I need to do in order to spend the rest of my life in the world of AML/CFT—and how I can do that in Mercari Group

I joined Merpay in March 2021. As I mentioned earlier, I had some understanding of fintech businesses through my experience at the FSA, and when I searched “Pay AML/CFT” online, I found out that Mercari Group carries out various AML/CFT-related initiatives and even has a system development team specialized in AML/CFT. That was why I applied to join Merpay.

In July of that same year, I was appointed to the position of manager of Mercoin’s AML & AFC Team, where I worked with team members and other relevant teams on establishing AML/CFT systems, including KYC methods applied at the time of opening accounts, as well as establishing customer due diligence measures on Merpay’s side. Then, in January 2023, I was appointed to the additional position of manager of Merpay’s AML R&C Team, which is in charge of AML/CFT at Merpay, and worked on strengthening the company’s AML/CFT structure.

Looking back on how I changed jobs over the years, I feel like I was absorbed in establishing my career when I was in my twenties. At the time, my career was just getting started, and I had to take the opportunities that appeared in front of me, which naturally narrowed down my choices and made it easier to jump right into a bold career change. To those around me, it may have seemed like everything was smooth sailing, but I actually had a serious complex about having jumped between careers when so many of the people I worked with had dedicated their entire careers to finance.
But I overcame that complex thanks to Mercari. Mercari emphasizes flexibility and diverse perspectives and values that go beyond stereotypical expectations, and not only accepted my career path, but taught me that it was a positive thing to have experience in different areas. I’m truly thankful to Mercari for this.

On the other hand, to be completely honest, I can’t say I’ve never thought about leaving to work elsewhere. The most advanced AML/CFT measures are born in Europe and the US, and I’ve dreamed of working at a European or US bank that examines its customers’ attributes and sales channels to manage them with detailed methods. I also prefer working as a specialist, but I’m in a management role now, which made me very uncertain as to whether this was really the right place for me.

But just as I was thinking about it, I saw news of a 101-year-old woman who was certified as the oldest pharmacist in the world. I was astonished, but at the same time, I began to think about what I needed to do in order to spend the rest of my life in the world of AML/CFT. I arrived at two answers.

The first was that detailed AML/CFT best practices are something I can learn at any time, so while I’m still physically strong, I should work to pioneer new areas where AML/CFT will be necessary in the future. The other was that if I find that there are things I can’t be involved in because I’m not a specialist, I should take them on myself by learning on my own or through my outside work as a consultant. As soon as I realized that with a little effort I could do both of those while working at Mercari, my worries disappeared, and I was ready to settle down.

Aiming to establish a group management system for handling AML/CFT and sanctions on a global level

Now that the concern is gone, I’ve been thinking about what I want to achieve in Mercari Group. The answer I came up with is building a structure to appropriately manage risks that Mercari Group faces, like money laundering and terrorist financing, both inside and outside of Japan.

Money laundering, to put it simply, is a process of changing the form of criminal proceeds so that the authorities can’t trace it and it can be used legally. As Mercari Group works toward its mission to circulate all forms of value to unleash the potential in all people, we provide various interconnected services, and plan to expand our services and scale going forward. While the ecosystem we envision is very appealing, it exposes us to the risk of fraudulent use leading to money laundering, the risk of people abusing our services for crime, and even the risk of facing economic sanctions.

The obligations of the team in charge of AML/CFT for Mercari’s financial businesses are to prevent, detect, and report criminals and transactions suspected of involving an inflow or transfer of criminal proceeds, as well as to establish and improve an appropriate and effective risk management system so that we can take the measures necessary to do so. In order to prevent and detect unusual or suspicious transactions occurring among Mercari Group services, close collaboration and mutual support across the Group, both within the team and with other teams, is essential. I think one of my jobs as manager is establishing an environment where stakeholders both inside and outside of the team don’t face any problems in their work and feel comfortable consulting each other.

We also work to assess risks and establish the necessary controls in areas not directly covered by the existing AML/CFT-related regulatory frameworks, such as Mercari Group’s on-demand work business. AML/CFT affects the UI/UX of a product, because it requires actions such as asking users to verify their identity and inquiring about transactions. Especially in cases that aren’t specifically required by regulations, we need to logically explain to the product side why such controls are necessary and what the risks are, and search for the solution that works best for both risk management and the product. While this coordination is challenging at a non-financial company, it’s something that I wouldn’t be able to experience working at a bank, and I think it’s one of the thrills of working in Mercari Group.

Looking outside the company, criminal techniques are getting more sophisticated by the day, and authorities both inside and outside of Japan are placing increasing importance on AML/CFT measures. If we wait until regulations are adopted, there’s a risk of the service being abused by criminals in the meantime, and if we have to suddenly respond to demands from external parties like the authorities, there’s a chance that: the measures we rush to put in place will be missing necessary requirements; and also they might not be the best specifications for the company. Not taking measures to prevent terrorist financing and proliferation financing also poses the risk of being impacted by regulations of other countries, such as economic sanctions, and not just the regulations of Japan.

That’s why I believe it’s important to not only consider cost-effectiveness and user safety/convenience, but unleash our perspective from existing domestic regulation frameworks and look to the long term when identifying issues, making plans, and driving them forward so that we can handle future risks. My dream is to establish a group management system for handling AML/CFT and sanction risks on a global level in order to fulfill our accountability toward stakeholders all over the world, and I hope to take on this task going forward.