Even though we are all aware of the challenges that the AML Compliance Officer faces throughout the country, certain markets bring specific peculiarities to its profile. The South Florida region would most definitely be one of those markets. The AML Officer Profile in South Florida is to say the least, complex.
In addition to being fully versed on the regulatory framework, and its ongoing developments and changes, there are some unique characteristics of the South Florida Region. For starters, the great majority of the AML Officers are bilingual; and in rare instances this is not the case, additional help needs to be hired to ensure this deficiency is well covered. And let’s not forget, those AML Officers that work in firms that cover the Brazilian market, which makes Portuguese also a necessity.
Language barriers are just the tip of the iceberg, cross-cultural understanding is an additional constant challenge. How many times have you seen a mailing address like this: Sr. John Doe, yellow house next to the bakery, no number… and had to actually accept it on the KYC. Being able to understand the challenges some Latin countries face in regards to kidnapping is another necessity. Unfortunately it is a reality that some AML Officers need to be sensitive and properly aware of in addition to the consequences if releasing funds to pay for a kidnapping ransom.
As the South Florida market covers a very affluent segment of the Latin population, you will rapidly have an understanding of what is to spend US$40,000 in one weekend and having to explain it to the custodial firm AML Officer that it was within normal expending parameters. And yes, it is normal to have a dedicated account for your travel expenses, and have those incoming funds flow from the Family Trust for those unexpected expenses. The last minute trip to the casino in “Punta Del Este” is something that happens.
This brings me to understanding the differences between an operating company and a PIC, the difference between a Foundation and a Corporation, a Short Form Trust or a Long Form Trust, and single items like knowing in which country will the father’s last name come in last, after the mother’s last name (any guesses?). My personal favorite, the ID that does not expire and you have a picture of a 10 year old trying to open the account for a grown adult.
South Florida has a diverse pool of AML officers. We see some from Chile, others from Richmond, VA. Some speak 5 languages, others “just” 2. Some service local branches, others are based here but oversee Latin offices. This group is certainly able to adjust and adapt to the constant changes affecting South Florida. I would say networking is also a necessary skill in the region, after all, you don’t need to know it all, but you should know who to call!
But there is one thing that is most certainly a constant about the AML Officer in the South Florida Region. They all must have a good sense of humor. After all, sometimes at the end of your day, all you can do is simply laugh about it.
