Meet Tom Armstrong, Compliance Advisor at TRM and Former Head of Financial Crime Compliance at Goldman Sachs

Prior to joining TRM in May, Mr. Armstrong led the strategic efforts to build Goldman Sachs’ first dedicated financial crime compliance team covering blockchain-based assets, and served in an advisory capacity across a number of business verticals including investment banking, private wealth, asset management, and global markets. Mr. Armstrong also co-led Goldman Sachs’ Transaction Surveillance team, and served as Head of the Financial Intelligence Unit and Forensics Group teams. Mr. Armstrong worked extensively on shaping the bank’s evolution into the crypto ecosystem, collaborating across the business to shape the necessary strategy from a financial crime perspective, and brings over a decade of experience in anti-money laundering and related compliance issues to TRM, the leading blockchain intelligence technology. Having dedicated his career to maximizing AML’s potential to detect and prevent illicit activity, Mr. Armstrong brings with him a wealth of knowledge about financial crime and the methods through which to combat it.

What was it like being on the compliance team in the early stages of crypto adoption at Goldman Sachs?

It was both incredibly challenging and equally exciting. The challenges for any institution entering this space are significant. The regulatory landscape is evolving, the business and use cases for adoption are developing in real time, you’re simultaneously trying to educate yourself and others on crypto, all while balancing a wide range of stakeholder opinions. Critically, there was no blueprint on how controls and compliance programs should be designed to mitigate the nuances in risk that crypto adoption presents to a traditional bank. That being said, the work was highly rewarding, providing me with an opportunity to truly think about and design an ideal control environment for a crypto compliance program from the ground up. 

Can you tell us about your role at TRM?

As Compliance Advisor, I will be supporting our private sector clients as they build and implement robust compliance programs. So far, that has ranged from outlining counterparty risk assessment frameworks to designing transaction monitoring uplifts.

We also supply our clients and the wider compliance community with training and resources on new risks and regulatory changes, so I'll be bringing my experience as a former practitioner to help shape and produce these materials. Additionally, I’ll be ensuring that TRM’s suite of intelligence and analytics tools reflect our clients’ evolving needs within the rapidly moving crypto landscape. 

What drove you to join TRM? 

For me, joining TRM is an opportunity to work with a highly skilled team that is making a real impact on AML technology and ultimately raising the bar for AML regimes. I’m fascinated by the idea that we are still in the relative infancy stage of this next world of financial development and subsequent compliance evolution. Every week there seems to be new regulation, new guidelines, new case law, and we’re seeing this acceleration of development play out in real time. To build out the next generation of innovative financial crime fighting tools in real time to empower our partners in law enforcement and institutions globally is incredibly energizing. 

The caliber of the TRM team was also a major factor in my decision. The team consists of a collection of the best talent from a variety of agencies and fields including the IRS, FBI, HSI, data scientists, compliance professionals and entrepreneurs. I love being in a collaborative workplace working towards a shared goal, surrounded by people who inspire me to be better. 

What excites you about the world of crypto compliance?

Historically, the AML industry has been very fragmented. There are silos between public and private sectors, between institutions, and even between different AML teams within the same institution.

With crypto AML, I’m starting to see signs that we are slowly chipping those barriers away. There are prosecutions involving crypto with textbook public-private collaboration, new ways to share information on wider sets of illicit networks and linkages, and blockchain intelligence tools that by their very design bring KYC, transaction monitoring, sanctions and other teams together in a much more holistic way. These are all really important shifts in the industry that we’ve been waiting to see for a long time.

There’s so much more to come and work to be done and I couldn’t be more excited for it.

What's a piece of advice you would give to someone building out a crypto compliance program?

Forging strong relationships with both regulators and the crypto business segments is absolutely crucial. This is true of compliance generally, but it’s more pronounced and critical with crypto opportunities. A lot is made of the technological advancements and promises of blockchain technology, but as with traditional compliance, relationships and people are still the most important resource.

Additionally, don’t forget the first principles of AML. It can be easy to get lost in all the technological nuances and advancements, and the constant stream of crypto headlines, but if you’re able to position your crypto compliance program on a robust set of first principles and augment where you identify new risks, it becomes much less daunting of a task.

Finally, remember that crypto compliance is an area where we are all undergoing continuous improvement, particularly seeing as this is a newer field than traditional compliance. Keep learning, keep testing new practices and find what works best for your institution and its unique situation.

Thanks for sharing; we're thrilled to have you on board!

For more on Tom catch him on TRM Talks: Hot Topics in Crypto Compliance.

Interested in a role at TRM? See our current openings here.