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[ PRACTICAL SOLUTIONS ]
Finally, including the business units into the risk assessment process upholds accountability and provides the line of business (LOB) an opportunity to address risks specific to business operations. Holding touchpoints with the LOBs provides much needed support during the data collection and information gathering process. In addition, it will ensure details in the risk assessment are accurate, and the LOB can effectively challenge findings and readily act against those findings. Finally, hold individual close-out meetings with all appro- priate staff and senior management to discuss the final risk assessment findings and action plans.
Staffing
Hiring within the AML field has seen an exponential growth in the past 10 years due in large part to inefficient monitoring technology as well as regulatory actions and expectations. This growth, and the pressure AML programs have been under, have made it difficult to place, train and provide a meaningful growth path for these hires. However, there are some successful methods that have been deployed to counteract these concerns.
When hiring new employees, placing significant weight on the individual’s thought process over experience can be fruitful. How an individual thinks can determine how they approach a topic――is it a puzzle to solve or a problem to fix? Finally, an individual should be teachable, willing to pursue learning and should challenge the status quo.
Consider moving to a staffing model that promotes collaboration. For example, many AML programs maintain separate AML investi- gation and enhanced due diligence (EDD) teams even though there is a lot of overlap in the work performed. One FI completed an overlap assessment that resulted in merging the teams to focus on all risks and typologies. The FI is also actively working on finding collaboration opportunities between the AML, economic sanctions and fraud teams to create a rapid response team that can focus on significant investigations. Both approaches have allowed employees broader careers paths and more challenging work.
Develop agile investigation teams well-versed on specific predicate crimes, AML/CTF national priorities and specific crimes within the FI’s footprint. Agile investigation teams should be responsive enough to handle any investigation, capable of supporting when a surge in alerts or EDD reviews occur and proactively seek out risks. More importantly, it can be a hindrance to place an employee in a role and leave them there. There can be a lot of value gained in exposing employees to other functions. Building a rotation schedule that allows employees to work on each team can bring new challenges, provide a fresh set of eyes on customer activity and identify process efficacies.
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