Page 48 - ACAMS-Today-V20N3

[ PRACTICAL SOLUTIONS ]
At one FI, an investigator had an interest in AML governance and risk assessments. As part of the rotation program, the investigator was able to assist with a project and as a result of the work product, was moved onto the team full time. In another instance, an investigator had interest in analytics and tuning but did not have a background in data science. The investigator developed a proposal on how they could support rule tuning from a non-data perspective by providing insights into why suspicious activity reports were being filed. After implementing the idea, the employee proved to be invaluable to the team and a new role was created. Thus, effectively prioritizing engagement can reduce the risk of burnout and promote cross-training.
AML programs should develop dedicated roles for tasks such as:
1. Keeping tabs on what is happening in the industry and the regulatory landscape
2. Apointofcontactforexams,audits and other reviews
3. Aprimaryliaisonwithlaw enforcement and other FIs
4. Qualityassurance/controltesting
5. Dataanalysts
6. Trainer
Finally, take the time to think through the big picture the AML program needs. When it comes to hiring, the default is to backfill a position, but is that adding value to the AML program? Where does the risk assessment guide the AML program, what are the merging risks? Staffing models are developing into more innovative structures that allow for agility within roles or the creation of new roles that can ultimately contribute to efficiencies. The AMLA promotes innovation, so embrace the opportunity to incorporate an innovative staffing model. If hiring is not plausible, seek out individuals within the organization that can contribute to efficiencies (e.g., a project manager or business developer) and build out investigative tools or automate data collection.
Training
After assessing needs through the risk assessment and putting the right staff in place, training needs to happen to make it all come together. While AML training opportunities have come a long way from basic online courses, effective and appropriate AML training is not easy. For example, AML conferences, where training is plentiful, are typically attended by senior AML managers. Hardly do junior staff or non-AML department employees attend and if they do, it is likely the one opportunity they will have, effectively cutting key staff off from these great training opportunities. While this happens for several reasons including cost, which could be hard to overcome, there are equitable training opportunities FIs can adopt.
One approach in building AML training curriculum for new hires is to require the employee to build a solid AML foundation of knowledge before they can advance. Rather than just being an “expert” at a specific job function, employees should understand the bigger picture and how their job function ties in. New hires should cross-train with other AML roles in order to understand and respect other AML department functions. One cross-training success involves the AML and the economic sanctions teams learning and working together about the function each team plays. This could include having the teams collaborate on case investigations that involve AML and economic sanctions risk. Cross-training can also provide a solution to closing a gap identified in the risk assessment.
Build highly customized and interactive training courses with real life examples that will have employees engaged. Explain why AML is important and how the “why” directly pertains to their role and business operations. Feedback from employees at one FI that took this approach has been extremely positive. The FI also regularly updates the training with new schemes or regulatory guidance/updates, preventing employees from taking a course with stale information.
Going one step beyond industry certifications, one FI developed an internal AML certification that focuses on the FI’s customers, products and services, geographic footprint, controls and risks. Employees can receive three certifica- tions, each with an increasing level of difficulty and time commitment. Successful completion of each comes with incentives (e.g., vacation days, pay increase). Employees walk away with a deep understanding of the risks faced by the FI.
48 [ JUNE-AUGUST 2021 ]