Chapter 6: Compliance Risk Management
Chapter 6
Compliance Risk Management
Valentina
New York, United States - November 1st, 2020
They bring me into an interrogation room. The air smells weird and my hands are still cuffed behind my back.
"Can you take these off of me before I sit down?"
A woman sits down in front of me and motions for me to do the same. It's not the policewoman from earlier.
She's looking at me like she's waiting for me to say something.
My instinct tells me to play stupid, so I do.
"Why am I being questioned? Can't I just pay a fine for being outside and go?"
She stands up with a frustrated sigh.
"Because of the drugs."
My stomach turns inside-out but my face doesn't move an inch. "I have no idea what you're talking about."
"Yeah? You have no idea how the drugs got on the ground? Should we go test you at the hospital?"
I call her bluff. "If you want to waste time and resources, sure."
She looks at me like she wants to say something else but decides against it. I feel uncomfortable sitting in an interrogation room dressed in a barely-there dress, but I'm here now and I have to get through it.
I wonder what Matteo is doing right now.
"Was it Matteo Giudice's cocaine?"
"I don't know where it came from."
"I don't know what you're talking about, or what it has to do with me."
The woman sits back down and places her gun on the table.
"What were you doing with him in that alley?"
"Talking."
"About what? Were you there so you could buy drugs from him?"
They have no idea about the party.
"We have a joint course at our university."
"So you meet up with him in random alleys after government imposed curfew so you can talk to him about your online course?"
"We-yes."
"Do you have any idea how that would sound in front of a judge?"
Is she trying to scare me?
"I know you can't charge me because of a bag on the floor."
"What if we run it for prints?"
"You won't find mine."
"Will we find Matteo Giudice's prints on there?"
"I can't say what you'll find. You'll have to do it yourselves."
"You were talking about your university course."
"Yes."
"Dressed up for an event?"
"That's how I dress."
"What if his story doesn't match yours?"
"I just hope that he got that phone call I was supposed to get twenty minutes ago."
She doesn't like the fact that I'm right so she lets me call my dad.
This is the worst
He sounds like I just woke him up. I have no idea what time it is, but last time I checked it was 2am.
"What's going on? What happened?"
"I'm at the police station, the 30th precinct, I think. It's in Upper Manhattan."
"Valentina?"
I hear rustling in the background, which means that he got out of bed.
"Did they put you in jail?"
"No."
"Alright. Stay there and don't say anything else. How long have you been there?"
"I don't know, they took my phone and put me in an interrogation room. Maybe thirty minutes?"
"Tell them they should've called your lawyer the moment you stepped foot into that room."
He hangs up, and the woman snatches the phone away from my hand.
I don't open my mouth for I don't know how long, but my dad walks into the room at some point, followed by one of the men from the poker game.
"Why is she in here without her lawyer present?" he turns to me. "You're free to go." He tells me in English.
"I'll be the judge of that." The woman says.
"Is she being charged for something?'
"Yes. She didn't respect the government imposed curfew, nor the rule-"
"Then we'll pay the fine. Valentina, come on."
The car ride is silent at first, with the two of them in the front and me in the back. My dad turns to look at me from the passenger seat.
"Aren't you going to ask me?"
He shrugs. "I just expected more from you Valentina."
"It was a friend's birthday." I try to reason with him while also hiding the fact that his disappointment hurts.
He shakes his head and turns to look at the road for a moment. "You being out when you know you shouldn't be, with a guy and a cocaine bag on the ground. You said you wanted to move to New York to be more independent and find out who you are. Is this your idea of who you are as an independent adult?"
I don't even know what to answer him, but I feel sad. He's sort of right, but everything is okay. Nothing happened.
"Will this go on my record?"
"You don't have a record. But they'll remember your name." the man answers.
It's the first time he spoke since we got in the car.
"What about Matteo?"
"Who?"
"The guy I was with. You're just left him there?"
"You're my daughter, Valentina. If it was anyone else I wouldn't have stepped foot in there."
"Is he the guy who played poker with us?" the man asks.
"Yes."
My dad looks at me. "Why?"
"What do you mean why?"
"Why were you in that alley with him?"
"We couldn't hear each other in the club. We weren't outside to do drugs."
"Who did the bag belong to?"
"I honestly don't know."
"Are you lying to me right now?"
"No."
The bag in the staff room is blue, not transparent.
"What happens now?"
The man answers. "Nothing. It was a half a gram of cocaine on the ground in an alley, they can't prove it's yours unless they check for fingerprints."
"What if they do?"
"Then you better hope you're telling me the truth."
I am telling the truth, but I think the bag might be Matteo's and I'm worried for him.
"You paid a fine for not respecting the rules. It's like a parking ticket, it doesn't go on your record."
"No, it's not like a parking ticket, Viktor. You shouldn't have been outside at that time of night. And it also doesn't mean that you can just go around doing drugs and 'talking' in alleys."
"I understand."
Before I go to sleep that night, I wonder whether Matteo is still there.
***
Tribeca, New York, United States – November 2nd, 2020
The office building of my dad's investment company is very close to the Statue of Liberty, which means it's two stations away from my home. The only downside is that there are a lot of tourists, and it's unusual for me to see so much energy at this time in the morning.
I barely managed to get out of bed and have my coffee before I had to be out the door.
I'm not made to wake up at eight.
The building has more levels than I can count, and I realize I've never seen it up until now.
I walk up to the woman in the lobby and read the name tag.
Ines
"I'm here for my internship?"
"Name?"
"Valentina Levin."
Something in her eyes changes when she hears my name.
"Right this way."
I follow her past the people standing by the elevators to the end of the hall. It's another elevator. The buttons are missing, having been replaced with a small screen.
"This is a private elevator for the executives." She explains as she presses a card against the screen.
We take the elevator up to the twenty-second floor; the last one. The elevator opens up into a large open space with a view of the Statue of Liberty. I'm a little overwhelmed by such big windows, showing how small the city below is.
There's a man I don't recognize sitting at the biggest desk, faced away from the window.
As I get closer I realize it's Viktor, the guy that drove my dad and I from the police station. I still haven't figured out what role he plays in all of this, but he's giving me lawyer vibes.
"Valentina, hi."
"Hi."
Ines goes back down with the elevator as I walk over to sit across from him.
"I'm Viktor, the Risk Compliance Manager at Levin Industries."
Does his job include driving my dad to the police station in the middle of the night?
"You'll be working as my assistant for the first month, so you can understand the job."
"I thought I was supposed to be a financial advisor trainee."
"We thought you'd be a better fit in Risk Management."
"Okay?"
Whatever that means.
"What do you want me to do today then?"
***
New York, United States – November 16th, 2020
The first week working with (or for) Viktor went by easily. All I have to do is join him during meetings; they were nonstop, each relating to completely different types of clients.
The government had officially lifted restrictions and allowed gatherings of up to ten people, which meant that face-to-face meetings were once again possible.
We met with some executives who tried to convince us to sell two buildings two them. Then there were real-estate developers trying to poach one of the listings and negotiate the price, and the endless entrepreneurs who all had ideas but no funds to put them into practice.
"What is your job exactly?"
Viktor looks over at my desk.
My 'office' is in the far-left corner of the room. The open spaces provide no privacy, but we're rarely at our desks anyway.
I'm literally just observing and using a very small portion of my brain.
"All we do is go to meetings and talk about who wants what for how much money."
"My job is to talk to these people and figure out whether it would be a good or a bad deal. If it's good, I bring it to your father. If it's bad, I don't bother."
"What's a good deal then? When do you even take decisions? I haven't seen you do anything else."
"A good deal is one that benefits the company long term. A bad one is a deal that would hurt us in any way. That's where the risk comes in."
"I thought compliance meant keeping up-"
"You can call it whatever you want, Valentina."
"Alright then. What decisions have you made?"
"It's not that easy."
"How long does it take?"
"At least five to six meetings, surveillance-"
"Surveillance? Five to six meetings? How can you even keep track of it?"
He sighs like there's too much to explain, but I have a lot of questions.
"If you're not going to teach me something, what's the point of me even showing up?"
He seems to like my question because he smiles.
"You're going to a meeting in five minutes. I can't attend because I have another engagement. I've already informed them of it, you can go."
The statement overwhelms me.
"Me? Can I at least have some background information?"
He brings over a folder.
"Is this the first meeting?"
He nods.
"Who is it?"
"I don't know. I've just received the appointment folder. The other guys cancelled, and I need to meet with your father down at the restaurant."
He hurries over to the elevator, making me regret asking in the first place.
GDC Corp.
Real-estate developers, construction
Room 118
I go down to the eleventh floor, room 8.
To my horror, people are already inside, gathered around a table for eight.
"Sorry for being late."
The man at the end of the table seems to be the leader, because everyone looks over to him.
I take the only empty seat left at the other end of the table, facing him.
Being the only woman in this room is weird
"That's alright."
He has an Italian accent, and he seems familiar.
"You're not Viktor." The man to his right states.
"I'm his assistant."
The two of them exchange looks. Another one opens his mouth.
"What is an assistant doing at one of these meetings?"
The leader raises his hand, as if to ask him to calm down.
"Who are you?"
"Valentina, who are you?"
He looks surprised.
"You didn't get our folder?" the man to his right chimes in again.
He's calmer than the other one. And he also somehow feels familiar.
"I did, but your names weren't on there. Just your business details."
"I'm Lorenzo, and this is my team at GDC Corporation. This is Franco, our compliance officer."
"Okay. This is my first meeting alone ever, so you'll have to let me know what it's about."
"Shouldn't we wait for someone more...equipped for this type of business?" another one asks, and they start a discussion in Italian that I can't understand.
"Excuse me." I say, but no one is even paying attention to me. "EXCUSE ME?!" I try again, this time raising my voice.
It makes them turn to me and shut up.
"I am here now, and I am Viktor's assistant. My job is to hear you out. Do you want something or are you going home? It's not that hard."
They all look stunned by my direct approach.
Lorenzo grins. "Aright." He looks at Franco.
Franco slides some papers over to me. They contain pie chart and photos of random, beat-up buildings somewhere in Manhattan.
"These three buildings are townhouses owned by your company for more than two decades. You haven't done anything with them." Franco stops to look at his boss before continuing. "You haven't used them nor flipped them in such a long time, and you're losing money paying the mortgage taxes. We want to take them off your hands and turn them into clubs."
I look through the papers, trying to see if I'd missed the offer.
"Where's the offer?"
Lorenzo takes out a folded paper from his breast pocket and stands up. Everyone watches him circle the table and come up to my right.
He crouches down so his elbows rest on the table, and it feels like he's patronizing me.
I take the paper from his hand.
$10.000.000
"Thanks for the offer. We'll need some time to consider it."
"Why wouldn't you accept it?" Franco asks me.
"These buildings are all in Manhattan and they're all around 500 square-meters, correct?"
Franco hesitates. "Yes."
"How much does a square meter cost in Manhattan?" Before they even begin to answer, I google it on my phone. "Fifteen thousand. One house is almost worth as much as the entire offer. It's way too low."
"Double it, then."
"That's still not enough. One house is worth that much. Why would we accept anything less than the fair price?"
Lorenzo cocks his head. "Now you're changing your policies?"
"I have no idea what policies you're talking about, because the ones we have clearly state that we'll be selling real estate at fair market price, unless agreed otherwise."
He walks back to his chair and straightens his jacket. Everyone on his team is looking at him.
"Alright." He finally speaks. "We'll be back next week."
He stands up first and the rest follow.
"What's your name?"
"Valentina."
"What's your full name?"
"Valentina Levin."
***
I tell Viktor about everything that happened as soon as I see him come into the office.
"You said they were new, but they asked for you by name. Did you send me in there on purpose?"
"I wanted to see if you could hold your own in a meeting."
"Why?"
"That's how you learn, Valentina." He drops down in his chair. "What did they say?"
I walk over to him. The space is way too big to have a two-person conversation from opposite sides of the room.
"I told them I'd get back to them, and they're coming back next week. Also, why can't this be done over the phone?"
"Everybody wants to get out of the house. And some things can't be settled over the phone."
Yes, illegal things.
"Why were they so sure that I would accept so little money? The guy said that we're changing our policies?"
"That's what he said?"
"Yes."
He looks worried. "And they asked for me by name?"
"Yes."
"Okay. No problem. I'll be there next time. Schedule the meeting for this Friday."
***
New York, United States – November 18th, 2020
I come out of the bathroom and lay down on my bed. The face mask I put on after I showered is making my skin itch, and I feel exhausted.
Viktor made me run around all day to collect spreadsheets about last month's financial situation from all departments in the building.
I take my phone out and take turns scrolling to all my social media, stopping when I see that Matteo has posted a photo.
It's one where his arm is around Ariana's shoulder, and they're both smiling at the camera with the Statue of Liberty in the background.
My finger hovers above the screen before I double tap to like it.
Matteo: are you in the corporate social responsibility class?
Valentina: yea
Matteo: okay
Nothing comes after that, so I decide to go take a bath and start a new book. It feels like it's been ages since I've had the time to just exist and do something purely out of joy. Or maybe I've never felt able to relax since Romeo got shot in front of me.
But right now, things are finally starting to settle down. I almost feel at home and safe in my new apartment.
Almost.
***
New York, United States – November 20th, 2020
Viktor and I are already sitting at the table when Lorenzo and Franco walk into the room, this time followed by only two men I don't recognize.
They all look more relaxed than they did last time, but the two men remain standing against a wall.
Franco and Lorenzo sit down across from us.
"Is it just the two of you?" Lorenzo asks.
I nod.
He pushes another piece of paper over the table towards me. A tattoo peeks out from under his suit. There's a scale on his wrist, exactly like the one Matteo has.
I take the paper, wondering why he didn't just pass it over to Viktor.
$15.000.000
"It's still not even close to market price. We can sell-"
"We're not selling at all." Viktor butts over me.
I look at him surprised. "But these houses lose the company money. What's the point?"
"We're not selling." Viktor repeats.
"Did you talk to dad?"
It slips out before I've had time to think. There's no logical explanation for why we shouldn't sell those houses.
"Yes, I did. We're not selling, and our decision is final. Thank you for taking the time."
Viktor stands up and I follow him out the room, confused.
"Why don't you want to negotiate? Isn't the whole point to make a profit?"
"That doesn't matter if the people you go into business with are a risk."
"So you know them? Who are they?"
"They're an Italian organization who is trying to spread out through New York. One of them was the CEO, and the other one is his cons-compliance officer."
"So, like you and dad."
He fidgets in his seat. "Exactly."
"Lorenzo is the boss, right?"
"Yes. GDC stands for his last name; Giudice."
I feel a tightening in my chest when the name comes out of his mouth.
"Lorenzo Giudice?"
"Yes. You've heard of him?"
I don't even know anymore.
"Who's the other one?" I ask instead of answering.
"I don't know. I haven't seen him before."
"Wait. How long have you been working here?"
"I replaced Mr. Volkov when he died."
"What did Mr. Volkov do?"
"He was your father's consultant."
"Did you know him well?
His eyes turn sad. "Yes."
I awkwardly look around the room, trying to find a way to change the subject. Luckily, he composes himself.
"So, there's no wiggle room on the deal?"
"No, we're not working with Italians."
His secretary walks into the room before I can fully process the depth of his words.
***
New York, United States – November 21st, 2020
Matteo: Do you have any notes in corp social responsibility so far?
The text comes while I'm reading on Sunday.
Valentina: *eye roll emoji*
Valentina: yes I do
Matteo: please?
Valentina: I'll email you
Matteo: thank uuuu
***
New York, United States – November 22nd, 2020
Matteo: Do we have a paper due tomorrow?
I groan as I read the text. The book is just getting to the part where the main characters get to have sex, and it's been the most excited I've been about romance in a while.
Valentina: yes
I place my phone upside down so I can focus on finishing the chapter.
Two pages later, the phone starts ringing. I've come to dread this ringtone at this point.
Matteo facetiming
"Yeees?" I sigh.
I can see his cheek and half of his eye, but I can tell he's started grinning.
"What?"
"Valentinaa."
He's like a child bluntly asking something of his parents he knows would take some convincing.
"Whaat."
"Is the essay for tomorrow the one thousand word one? I can see two in the assignments tab."
"Yes."
"Have you written it?"
"Yes."
The camera moves away from half of his face to show his entire face now. He's sitting on a couch, with a headset around his neck.
He was playing video games. Of course he was.
"Can you-"
"I'm not going to write it for you."
He pretends to be offended. "I wasn't going to say that!"
He sounds genuine, and his Italian accent makes everything even funnier. I smile.
"What do you want then?"
"Can I-"
"You're not going to copy-"
"Will you let me finish?!"
I roll my eyes and nod for him to continue.
"Can I copy it?"
"No."
He groans.
"What will it take for you to help me?"
"I never said I wouldn't help you."
He smiles. "How?"
"Just run the assignment through an AI or something. They can do your essays."
"Are you serious?"
"Yeah."
He sets his phone on the table in front of him, which reveals his entire body. He's wearing a simple white tee that reveals some tattoos peeking from under it and sweatpants.
Objectively, he looks good as fuck.
Matteo pulls his laptop over his lap and starts typing. A couple of minutes later, he looks back at the screen.
"Shit, Valentina, this is the best!"
I smile at his excitement.
"Thank youuu. I owe you one."
"I'll keep that in mind."
He winks and ends the call.
I change the ringtone before I put my phone on do not disturb and get back to my book.
***
New York, United States - November 25th, 2020
I'm trying to find ways to keep myself entertained once I'm back from the office.
My phone buzzes when I'm in the bath, high as I smoke a joint and finishing the book I started.
Matteo: I submitted it on time btw
Valentina: Good for u
I smile.
Valentina: you look happy and healthy
Matteo: ?
Valentina: Not me, if you ever cared to ask
This seems like the funniest shit in the world right now.
Matteo: ask you what
Matteo: you didn't submit the paper?
Valentina: Good for u youre doing great out there without me baby
Matteo: ??
Matteo facetiming
His face comes on the screen.
"I'm taking a bath."
"I can see that."
"I'm high."
He smiles. "That explains the texts."
I take another drag from the joint as I stare at the screen. Judging by his suit, he's definitely not at home.
"What are you doing?"
"I'm on a job with Luca."
"I'm on vacation until next week. Extended Thanksgiving weekend."
"Shit, right. Thanksgiving. Yeah, it's my only job this week too."
We both stare at the phone without saying anything for a while.
"So...what?" I say when he grins at the screen.
"You really are high."
Someone off screen says something in Italian to him, and I know it's Luca without having to see him.
"I have to go."
"Okay."
He ends the call, but I keep staring at the screen for a long time, my mind elsewhere.
Someone rings the doorbell, and I'm in no mood to get out of bed to answer it.
Also, who the fuck can it be at this hour? And how did they get into the building without me buzzing them in?
I groan as I get out of bed and walk out into the hallway to get to the door.
My hand hovers on the doorknob as I look through the peephole.
The hallway is too dark for me to figure out who it is.
"Who is it?" I ask.
"Me."
My body grows instantly hot when I hear Matteo's voice through the door.
I open the door to look at him standing there, still wearing his suit.
"What?"
He walks past me into the hallway, and I close the door, still confused.
His eyes fall on my lace night dress.
"Take your dress off."
My body tenses at his words, shocked that they actually came out of his mouth.
He's less than a meter away from me, and I wonder whether he can feel how much I want to kiss him right now.
His eyebrows raise when he sees me not reacting.
My hands go down to the hem of my dress before it falls to the floor with a soft thud.
"Get on your knees."
"Fuck you."
He grins, like he was expecting the reaction from me. "You'd like to, I know."
Excuse you?
My face expresses my thoughts, which makes his grin widen even more.
"But you'd never admit it."
My mouth drops, but I don't deny it. Instead, I watch him cross his hands around his back.
"After you admit it, you can do whatever you want to me."
He says it so bluntly and without shame it makes him even more attractive.
Damn.
I watch him walk down the hallway until he gets to my room.
I follow him just to watch him he sits down on the bed. He leans back against his palms and looks up at me with a daring smile. It's that boyish smile that makes him look youthful.
It's his best one.
My head tilts as we look at each other.
Oh really?
I step closer, wanting to see how long it would take for him to cave and call it off.
One of my knees comes to rest between his thighs, the other foot still firmly planted on the floor.
My hands go to his shoulders, and he places his on my hips. The contact of his palms against my bare skin scorches me.
He's looking at me as if he were daring me to continue because he wants me to be the one to make the first move.
"Stop looking at me."
"Never."
I straddle him without thinking twice about it, and he stiffens under me at the sudden movement.
His hands move under my dress, coming to rest on my thighs. I run my tongue over my dry lips, and his eyes turn to them.
"Your turn." I say.
His fingers press into the skin of my thighs. "Admit it."
"Admit what?"
That conversation seems like it's in the distant past.
"You're attracted to me, Valentina."
I kiss him for the sole purpose of getting him to stop smirking at me like that.
When I finally pull my head away, his grip tightens on my thighs to make sure I'm not going anywhere.
"And what happens if I admit it?"
His eyes fall to my lips.
"Whatever you want."
The doorbell rings again, and I wake up.
I blink for a few moments, the picture of Matteo in my room suddenly gone.
Light is coming through the crack between the curtains.
I make sure to put my robe over the night dress I'm wearing as I walk to the front door.
A USPS delivery guy is looking down at something.
I open the door. "Hello?"
"I have a delivery for..." he looks down at the name on the box. "Valentina Levin?"
"Yes, that's me."
He hands me the box before he turns around and leaves.
I unbox the package in the kitchen. It's some books and other stuff I've asked my mom to send over that I completely forgot about.
As I get the stuff out of the box and place it around the apartment, the only thing I can really focus on is not thinking about the dream I just had.
I haven't dreamt about Matteo since last summer, and I haven't even thought about him in a more-than-an-friend way.
It's from the weed.
By the time the sun sets I'm already bored out of my mind. And it's not even Friday yet, which means that there are three full days left until I will interact with another human being.
Adrik is back in Russia, so there's no one really - except for Matteo – who I can meet with.
The screen of my phone lights up next to me on the bed.
Matteo: Im bored
Valentina: me too
Matteo: want to come over?
I've never actually – actually, I have hung out with him alone before since Italy.
Our short time together in jail or the ride home.
What would we even talk about?
Matteo: I have wine.
Matteo: And weed.
I smile at the message.
You're overthinking it
Nothing has to happen
It was just a dream
We're friends
It's normal
He hangs out with Isabella all the time and they don't do anything
It's okay
Valentina: Okay.
--
Yaaay i'm back to writing on this! I missed it :)
Hope you enjoyed!
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