When I was in Italy a few years ago I met a nice couple at a café who was on their way back from a year-long world tour. My first thought was: how can they afford to take a year off of work to travel the world? I figured that they must be people of means. After chatting with them for a while and doing my due diligence, I learned that they had quit their successful jobs in New York and had decided to use their savings to travel the world. So I was partially correct in my assumption. It reinforced the notion that money travels.
In the compliance field we are taught to perform due diligence on potential clients, and unlike the couple I met in Italy sometimes individuals traveling to different countries have other things than sightseeing in mind. They might be seeking citizenship through citizenship investment programs and may have obtained their high net worth through criminal activities. The headline article Investing in citizenship explores the opportunities given to high net worth individuals to obtain residency or citizenship in other countries through investment programs. The article deals with recent international trends, challenges in the customer identification program (CIP) and the risks posed to national governments when proper investigative due diligence is not conducted on possible candidates.
The second cover article SAR-By Committee discusses the steps a financial institution should take when forming a proper SAR committee, such as the composition and the appropriate decision-making process of the committee.
This issue contains articles about training, ranging from how-to balance your career and education to embracing conflict. The article The AML working group highlights the importance of cooperation and communication in the compliance field and how key stakeholders within the organization should be part of the working group. Target training discusses the importance of BSA/AML reviews and the testing of your employees to better gauge their comprehension of BSA/AML job functions. The article further explains that target training will help you identify gaps that you may have in your departments or with individuals and explains the type of training you should be providing for your employees.
ACAMS Today had the opportunity to interview Attorney General Catherine Cortez Masto of Nevada, USA and discuss steps the state of Nevada has taken against elder and drug abuse and how Nevada has created important partnerships with rural communities. Another important interview was conducted with Seehanat Prayoonrat, the secretary-general of the anti-money laundering office in Thailand’s FIU. Prayoonrat discusses the critical AML challenges facing Asia and more specifically his vision for AML development in Thailand. This issue also contains an in-depth interview with ACAMS 15,000 member, Kim Garner from MoneyGram.
We hope to see you in March at the 18th Annual International AML & Financial Crime Conference in Hollywood, Florida. Bon Voyage!
Karla Monterrosa-Yancey, CAMS,