ACAMS is more than a career booster—it is a personal experience.
The days following 9/11, no matter our location, we all felt a lot of things were on the brink of change in this world. In February 2002, my boss asked me to ensure we implemented the USA PATRIOT Act in our practices, to be established only a month after the terrible events of September 11. At the time, I did not fully understand his directive or its significance. Back then, my role was as head of the financial division of Citibank's Asset Management and Pensions Funds Business in Panama.
It was only after attending a seminar from the Financial Action Task Force (FATF) in Panama that I understood how my career was going to change and more importantly, how the role of the compliance officer was about to see a sharp difference in its versatility. I recall how all the Panamanian financial entities were represented with their respective and recently appointed ‘compliance officers.’ During a conversation with a few of them, we all questioned: what is a compliance officer? Two years later in 2004, at a similar seminar in Paris, I noticed that French compliance officers were asking themselves the same question.
The experience of the seminar in Panama made me aware of the importance of the subject—learning FATF’s then 40 + 8 Recommendations (the recommendations were recently amended to 40 technical ratings and 11 effective scores). These ratings are the baseline for setting standards and promoting the effective implementation of legal, regulatory and operational measures to combat money laundering, terrorist financing and other threats related to the integrity of the international financial system.
In addition to FATF’s establishment in 1989 as an important intergovernmental body, the new framework provided by Sec. 352 of USA PATRIOT Act1 states that the role of the compliance officer and the anti-money laundering (AML) programs is as follows:
'Requires financial institutions to establish anti-money laundering programs, which at a minimum must include: the development of internal policies, procedures and controls; designation of a compliance officer; an ongoing employee training program; and an independent audit function to test programs.'
As my peers in the financial sector were wondering about the core of their future roles, I was already thinking of who would be auditing them. Auditors are commonly specialized in accounting as opposed to anti-money laundering controls. In fact, in those days, no one knew how to audit compliance. Therefore, given the gravity of the issue, I decided to change my career path and became a compliance auditor. While the French compliance officers at the 2004 seminar wondered about their future roles, I was already enrolled in a program to eventually become their auditor.
Certainly, I would not have achieved the same success without ACAMS. Soon after accepting my double role as head of finance and compliance, I started to search for information on how to become an auditor for compliance officers. I thought about how the law was quickly changing and how consequently our roles as AML and compliance professionals must adapt to keep pace. I noticed that the role of the compliance officer was not one that fell strictly under the expertise of lawyers, accountants or auditors. When it came to compliance/AML, no one knew what to audit, and this is where I found the versatility of the job.
There was not a single university in the United States or Europe that could provide me the skills to become a compliance auditor. Fortunately, in 2003, I discovered ACAMS. It was exactly what I was looking for and I understood perfectly the essence and purpose of this association. I decided to leave Citibank in Panama and moved to France. In addition, I became an ACAMS member. Thanks to my French background, I managed to enroll in an auditing program at the prestigious Ecole Superior de Commerce (ESC) in France. This was not an easy decision because I was 42 years old with two kids and a baby. Although I challenged myself by changing careers, I was confident that the work that I would be doing was of great importance and impact.
During my two years in the program, I learned audit methodologies and was able to learn how to implement an AML program thanks to my Certified Anti-Money Laundering Specialist (CAMS) certification. Once I developed these skills and three months prior to graduating, I decided to explore job opportunities by sending my resume to a few banks in France and the UK. I knocked on the doors of several human resources departments, none of which were able to understand what I was looking for because positions for compliance auditors had not yet come into existence in 2005.
With the help of the ACAMS’ network, I managed to obtain the email addresses of the chief auditor at Citibank’s Europe, the Middle East and Africa (EMEA) region and the chief auditor of Western Union. Unfortunately, I had to put the completion of my ESC auditing program on hold as Citibank rushed to hire me. During my interviews, there were no questions about auditing skills; instead, all questions were related to AML/compliance. All my answers to the interviewers’ questions were learned during the CAMS certification program—no Citibank experience or auditing program skills mattered during these interviews. The interviewers were surprised at what I knew, theoretically, and were confident that I was prepared to implement and audit the AML program. Soon after, I gladly joined Citibank’s glamorous EMEA audit and risk review (ARR) team based in the UK as audit manager and compliance/AML subject-matter expert.
Just recently, I learned that back in 2005, I was among the first CAMS in Europe and the only one at Citibank in Europe. I would like to once again thank ACAMS and the CAMS certification program, which boosted my career in the early years of compliance/AML.
Mario E. Aguilar-Nino, country AMLCO for Belgium, Netherlands deputy AMLCO
Institutional Clients Group, Citibank Europe plc., firstname.lastname@example.org
- “USA PATRIOT Act,” FinCEN, https://www.fincen.gov/resources/statutes-regulations/usa-patriot-act