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A cost-saving approach to industry conferences is to create an internal AML conference that focuses on the FI’s specific risks as well as industry-related risk and practices. Invite staff from the AML department and the LOB as speakers and/or attendees. External speakers from local law enforcement, anti-human trafficking organizations, etc., can provide great value and interest. One FI even included a mock investigation, challenging teams to find the most red flags in the shortest amount of time.
Develop a training program that provides all AML employees various external training opportunities including earning industry certifications. For example, junior investigators are required to attend at least four webinars and one conference/ seminar per year. Senior investigators are required to attend four webinars, two conferences/seminars, one peer group meeting and attain a certification within 24 months.
Training AML staff should not be limited to the latest AML/CTF typologies. If an FI wants longevity from employees, expanding their engagement beyond the walls of the AML program can pay dividends. Offer collaboration with other LOBs on projects or day-to-day functions. For example, an FI partnered with the compliance department to perform testing for 10 to 30 hours a year. This has driven positive engagement on all fronts by providing AML staff new experiences and understanding of the organization while supporting an LOB that is short on resources. Another FI built a rotational AML program where AML and non-AML staff change positions to learn more about each other’s roles (i.e., Walk-A-Mile).
Finally, do not forget leadership devel- opment. Focusing on communication to build confidence and better commu- nicate with LOB staff on information requests or sit on organizational projects with senior leaders can go a long way. It demonstrates the FI’s commitment and investment in employees and builds on employee engagement. An engaged employee can add tremendous value to the AML program.
Value for law enforcement
With the passage of the AMLA and FinCEN’s ANPRM, collaboration, transparency and information sharing between the private and public sectors should see a big boost. The first positive impact is the issuance of the AML/CTF strategic priorities. As such, the three foundational aspects of an AML program will be critical for FIs in adopting and executing an innovative, risk-based AML program that targets the AML/CTF strategic priorities faced by their FI and ultimately provides law enforcement with information that has a “high degree of usefulness.” These efforts should also lead to state and local law enforcement agencies (e.g., regional FBI, Post Master Inspector General, IRS-Criminal Investigation) fostering stronger and open relationships. This allows for an opportunity to better understand what region-specific typologies are a focus, assess if the AML program has a means to detect or control the associated risk, and get the right information into the hands of law enforcement.
A lot of good will come out of the AMLA and FinCEN’s ANPRM, however, it is up to the FIs and law enforcement to execute on these opportunities. Building a strong foundation will help in achieving that goal.
Conclusion
The ideas shared by these forward-thinking AML professionals are by no means exhaustive. The intent of this information is to lay the foundational framework by performing a needs assessment through the risk assessment, hiring and placing the right staff, as well as providing the proper initial and ongoing training. These three elements will feed into the rest of an FI’s AML program, allowing for the movement toward a more effective, risk-based AML program. Finally, no matter where an FI is at in the maturity of their AML program development, taking a step back to truly assess these three areas, and where improvements can bring value to the AML program, should be a continuous effort.
Part two will focus on how to bring value to an AML program from a technology, data and process perspective.
Chris Bagnall, CAMS-FCI, CFE, Sojourn Technologies, Bagnall@sojourn-technologies.com Jamie Thomas, CAMS-FCI, Fulton Bank, jthomas@fultonbank.com
1 “Now That Christie’s Has Sold An NFT For $69.3 Million, The Time Has Come For Artists To Make NFTs Meaningful,” Forbes, March 16, 2021, https://www.forbes.com/sites/jonathonkeats/2021/03/16/ now-that-christies-has-sold-an-nft-for-693-million-the-time-has-come-for-artists-to-make-nfts- meaningful/?sh=7c4b3b473f70
2 “H.R. 6395 (116th): National Defense Authorization Act for Fiscal Year 2021,” U.S. Government Publishing Office, December 2020, https://docs.house.gov/billsthisweek/20201207/CRPT-116hrpt617.pdf. Stakeholders include, but are not limited to, federal functional regulators, law enforcement authorities, financial institutions, technology experts, intelligence community, etc.
3 “National Strategy for Combating Terrorist and Other Illicit Financing,” U.S. Department of the Treasury, 2020, https://home.treasury.gov/system/files/136/National-Strategy-to-Counter-Illicit-Financev2.pdf
4 Valentina Pasquali, “FinCEN Anticipates Busy Regulatory Year,” ACAMS Moneylaundering.com, April 13, 2021, https://www.moneylaundering.com/news/fincen-anticipates-busy-regulatory-year/
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