Prepared Remarks of
ACAMS Executive Vice President
ACAMS Ireland Chapter Launch
January 14, 2016
The Myriad of Challenges for AML Professionals in 2016 and Beyond
Ladies and Gentlemen, I am truly honored to be joining you tonight to launch the ACAMS Ireland Chapter. On a personal level, this is the birthplace of one of my grandfathers, who came from Sligo in 1920, and my great grandfather who came to the US in the late 1800’s from Carlow. In 2008, I was also named one of the Wall Street 50 by Irish America magazine, a recognition that instilled me with pride. So being in Dublin for this auspicious start to what I know will be a tremendous chapter means a great deal.
On an ACAMS level, chapters are a perfect example of what ACAMS stands for—an AML community of private and public sector experts organizing to share information, challenges and strategies for addressing all aspects of financial crime, sanctions and money laundering. Whether it is in traditional banking, MSBs, the burgeoning FinTech community, AML solution providers or law enforcement and regulators, all of you participate to improve the AML community. ACAMS members in Ireland and throughout the globe will clearly benefit from your collective commitment and insight.
2015 AML Issues
Where are we after the experiences of 2015?
Sadly, there continues to be horrific events around the world that attack every fabric of our society, such as the cowardly acts in Jakarta last evening. Whether terrorists, human or drug traffickers, or purveyors of fraud against the elderly—all of these heinous acts need money to commit their crimes against the innocent. Experience tells me that the AML community is uniquely situated to combat these and other acts that need illicit funds to thrive. We must, however, continue to learn to work and grow together because only the partnership of the private and public sectors can lead to AML success.
The state of the AML community is strong regarding partnerships so I am confident this will only improve.
In addition, the global AML private sector continues to face some high priced enforcement actions, reputation risk and increased regulatory criticisms in all parts of the financial service provider community.
It is not useful to only say that institutions need to improve, but instead what is also needed is clarity on regulatory expectations and some changes to existing law.
We must change the “tick-the-box” mentality on AML compliance. Partnerships here are also essential.
If all of the above were not challenging enough, the AML professionals face more calls for criminal penalties against individuals; an issue that I know European AML professionals already have had to adjust and address. To be clear, I have no issue with the last point but how will it occur? If the AML/BSA/MLRO officers are now targets two things need to happen: more internal authority for those in charge of AML and a better strategy of communicating AML successes to policy makers, the media and the public.
We have a great story to tell—let’s not fear the facts.
And, of course, an improved private-public sector dialogue can focus on how best to communicate our collective successes.
A Call for Action
Those of us that have been part of the anti-money laundering area pre and post September 11th and other well-known dates where terrorist attacks have occurred throughout the world, know that many of the laws and regulations created are the result of a patchwork of changes added one after another on existing requirements. There is no real example of any lessening or limiting of all these AML rules despite so many new products, services, delivery channels and an enhanced reliance on technology. In addition, the so-called “debate” on de-risking is, in my opinion, completely one-sided. Financial institutions are the only players being criticized for exiting or for not on-boarding accounts due to risk issues and all you hear from parts of some governments and global organizations are that certain categories of customers are high-risk without any useful recommendations regarding mitigation. Add to that, the economic concern about the need for financial inclusion, without those policy leaders that advocate for change offering any assistance, and you realize that this important issue needs a change in strategy.
So what do we need in 2016?
ACAMS has previously called for an AML Executive Summit in the United States where everything is on the table for discussion—exam inconsistencies, culture, the SAR/STR regime, other reporting requirements, the risk-based approach and risk assessment deference. This is a global problem; however, so many AML communities need to work on addressing the relative silence and offer solutions.
Let us continue to push for dialogue between the private and public sectors throughout the world—a thorough, frank and comprehensive review of how we pursue terrorists, fraudsters and other criminals that abuse society through the financial sector.
To our friends and colleagues here in Ireland, thank you for your commitment to AML. We know this profession is not simply a job but a passion because when we succeed, we protect and improve society.
Congratulations on today’s launch. We are all better off because of your efforts.