Because money laundering often involves transactions through one or more financial institutions, financial institutions are a prime target for anti-money laws and regulations. But it is evident from a quick glance at AML’s two main regulations (the Bank Secrecy Act1 and the USA PATRIOT Act2) that other industries such as money services businesses and casinos also have strict AML compliance expectations.
Tip: Don’t limit potential AML employment opportunities by limiting your search to a specific industry! While federal banking regulators are certainly interested in the AML compliance programs of the institutions for which they have oversight, other industries also require AML program adherence. Consider working for a casino, money service business, broker-dealer, consulting firm or external vendor as an alternative to a financial institution.
AML as a career will, undoubtedly, offer something to pique your interest and use the skills you’ve honed in your law enforcement career. Surveillance (finding the bad guy) is what most laypeople think of when AML is mentioned. Surveillance itself has multiple components including, of course, the investigators. Investigators are the people who decode the suspicious activity indicators (red flags) for evidence of naughtiness, find people who have violated currency reporting requirements or are Politically Exposed Persons (PEPs). In law enforcement lingo, investigators might be considered detectives or agents. Investigators get an assignment, conduct an investigation, and potentially make some decisions, for example file a Currency Transaction Report (CTR)3 or Suspicious Activity Report (SAR)4, close one or more accounts or contact law enforcement. In addition, some institutions have Financial Intelligence or Investigative Units which can be considered the SWAT team for investigators.
There are multiple Information Technology (IT) components to a quality AML program and IT is a critical component of an effective AML program. In short, IT makes it happen. IT is often responsible for automating the investigation process (including list screening), required reporting and document retention. The IT function can be located within an organization or be an external vendor.
Governance is an internal oversight function and also plays an essential role in the operation of an effective AML program. A governance team is responsible for conducting and analyzing risk assessments5, compiling and presenting senior management reporting, performing research and analysis, advising line of business on key AML-related matters, and interacting with the auditors and examiners who, similar to law enforcement, validate compliance with laws and regulations and impose penalties for violations.
Tip: Don’t limit potential AML employment opportunities by focusing only on Surveillance. If you have mad computer skills, consider IT. If you have an accounting or audit background, consider audit or examination work. If you have great interpersonal skills and attention to detail, consider a governance career.
Concerned because you can spell AML but can’t readily define it? Don’t be, there are multiple sources of information to get you up to speed, and many of them are free! Bookmark the Financial Crimes Enforcement Network (FinCEN) website6. FinCEN is the Financial Intelligence Unit for the United States and is the receiver of SAR and CTR filings. Understand that the skills and knowledge needed to write an effective SAR is very different from the knowledge needed to effectively use a SAR or even write a police report. The SAR Activity Review is a periodic FinCEN publication (accessed from the website) that provides well-grounded information, case studies and guidance on drafting effective SARs. FinCEN also publishes trends based upon their analysis of filed SARs.
The Association of Certified Anti-Money Laundering Specialists (ACAMS) is the preeminent source for AML information! Through their two publications (ACAMS Today and ACAMS Connection), ACAMS provides current information on AML trends, hot topics, regulatory updates and more. Visit the ACAMS website at www.acams.org to learn more.
The Federal Financial Institutions Examination Council (FFIEC) Bank Secrecy Act/Anti-Money Laundering Handbook7 provides a holistic view of how financial institutions will be examined and what each institution is expected to do to be considered in compliance with BSA and supporting regulations.
Want to think big? The Financial Action Task Force (FATF) provides an international view into money laundering and anti-money laundering efforts. In addition to being a policy-making body, FATF publishes numerous white-papers, typologies and recommendations on its website8 (Extra tip: if you take the exam to become a Certified Anti-Money Laundering Specialist, be sure to learn and understand the FATF recommendations located on the website to increase your knowledge and chance of successful completion of the exam!)
If you’re considering a career in financial services, you may want
to visit the American Bankers Association website or the BANKERSONLINE website for AML-related information specific to the banking industry. The Department of the Treasury hosts the Terrorism and Financial Intelligence website9 on which you will find Office of Foreign Assets Control (OFAC) two more fantastic, free AML resources.
Tip: Do your research well before interviewing for a position! When lacking in direct AML work experience, compensate with knowledge. AML regulations don’t change often, but the interpretation of what is needed to do to comply with the regulations is nothing but high-velocity change. Arm yourself with knowledge and you’ll be well-positioned for a successful interview. “Prepare two to three years in advance” advises McDonald, “Build your resume and credentials.”
Tip #4 and #5
If you are willing to spend money and time investing in your future AML career, there are a host of aids available for preparation. To begin with, join networks of like-minded individuals. ACAMS is one such group. In addition to providing learning events on a national level (webinars, live chats and conferences), ACAMS has numerous local chapters that offer targeted learning and networking opportunities. The Certified Anti-Money Laundering Specialist (CAMS) designation is the preeminent anti-money laundering certification. Preview AML job postings, the majority will require you hold the CAMS designation or similar money laundering specific certification. The ACAMS website has the added bonus of highlighting open AML positions.
In addition to ACAMS, there are other networking and/or certification offering organizations in which you may want to consider investing time or money. The Association of Certified Fraud Examiners (ACFE)10 is one such organization. Over the past five years or so, anti-fraud efforts and AML have been closely linked. FRAML is the new “hot” acronym for the combination of fraud detection processes and AML solutions to gain efficiencies in order to lower costs and increase risk coverage.
A fantastic place to find hiring managers, especially if you are willing to relocate, is at national conferences. ACAMS hosts an annual national conference in September that brings together AML professionals, vendors, consultants and law enforcement personnel from all over the world. In addition, ACAMS and moneylaundering.com (http://www.moneylaundering.com) partner for a spring conference annually. The guest speakers at both conferences are experts in the AML field. The opportunity to get up close and personal with the experts is really not to be missed!
“Reach out to other retired law enforcement officers who have successfully transitioned to the private sector.” offers James P. Meade, a 31-year veteran of the Henrico County Virginia Division of Police and current Investigative Support Manager for the National White Collar Crime Center. Michael McDonald adds that both current and former prosecutors are also excellent resources as they know the applicable anti-money laundering statutes and will often provide candid advice and feedback.
Tip: Network, Network, Network! The more contacts you make, the more likely you are to hear of open positions even before the opening is made public. Consider joining the board of a local chapter to hone your knowledge and meet more AML professionals!
Tip: Consider becoming certified before you begin your job hunt! This tip comes with a caveat: Many hiring organizations will permit you a specified period of time to obtain a designated certification and will often pay for the training and subsequent test. “Having the CAMS certification or other anti-money laundering or fraud certification upfront will be a positive differentiator between applicants that a hiring manager will certainly consider” states Joe Soniat, former Finance Officer US Intelligence Agency and Bank Secrecy Act Officer at Union First Market Bankshares, located in Richmond, VA.
Transitioning from law enforcement to an AML-related position isn’t solely about changing your role. Each hiring organization has its own culture. A law enforcement culture can be viewed as being somewhat militaristic. Most likely, the culture at the hiring organization will not be based on issuing or receiving commands. Many hiring organizations offer flexible work arrangements, telecommuting, job shares, ride shares and numerous other employee-centric attributes or services. Adjusting to a culture change may not be as simple as replacing a gun belt with an employee-identification badge. Often in law enforcement, life and death decisions need to be made instantly. In the private sector, employees are granted time to make appropriate decisions. A good decision in the private sector is not always the fastest decision.
In law enforcement there is a beginning (a complaint), a middle (an investigation) and an end (an arrest), not so with AML. More often than not in AML, the AML-professional does not see the outcome of his/her efforts. When a SAR or CTR is filed, law enforcement does not come back to the filer to update the status of the case or congratulate the discovery of wrongdoing. Every once in a while, an AML-professional may obtain “closure” through reading about an arrest in the paper or online but remember &mdash confidentiality prohibits the AML-professional from ever indicating that the suspect was in his/her sights.
Tip: Invest time in learning a new model of personal interactions. Understanding your new culture and learning what is required to comply with human resource policies is a key to successful integration in your new career. Ask your private-sector friends about working conditions that you might expect:
A career change necessitates introspection to examine both needs and interests. Perhaps you need a flexible work schedule or company provided health insurance. When conducting a job search, ensure the potential opportunities you select fulfills your identified needs. If you’ve really excelled in investigations or information technology, concentrate on job opportunities that will keep your interest and utilize your strengths. While a career change certainly offers the opportunity to reinvent yourself, a position that does not fulfill needs or wants is not likely to lead to success.
Tip: Ensure you select potential opportunities that match your predefined criteria. Investigate the type of position, the organization and, when possible, the hiring manager to increase your chance of a successful match. Just as potential employers will investigate your work experience and qualifications, you would be remiss not to do the same of the employer. A bad match won’t end well for anyone.
In conclusion, preplanning and preparing for an AML career is time well-spent! The more information you have about AML, the types of roles, potential employers and your own needs and desires, the more likely you are to start your career on the right path. Remember to draw on all available resources in order to help eliminate false starts. Good luck as you start your journey to a new career.
Jean-Ann Murphy, CAMS, USA,
send comments to firstname.lastname@example.org
- http://www.fincen.gov/forms/files/fin104_ctr.pdf (for depository institution)
- http://www.fincen.gov/forms/files/f9022-47_sar-di.pdf (for depository institution)