The ACAMS 11th Annual AML and Financial Crime Conference held in Las Vegas in October was the best I ever attended. With over 1,500 people from across the globe participating in the three-day event, the ACAMS staff once again stepped up and hosted a world-class conference.
My first observation is that transition has been completed. Financial crimes discussions and sessions were seamlessly integrated with anti-money laundering. Probably the best symbol of this transition was the address by keynote speaker Richard Weber. Many of you may know Weber from his tenure at the U.S. Department of Justice or his service at the New York County District Attorneys Office (Manhattan DA) working for and with Cyrus Vance and Adam Kaufman. Well, Rich is now a rock star!
In his new position as chief of criminal investigations for the United States Internal Revenue Service (IRS), Weber commands thousands of criminal investigators worldwide. The theme of his keynote speech at the conference was the need for all of us in the AML and financial crimes community to work together to combat domestic and international financial crime. Years ago, the common opinion was that tax evasion and other financial crimes were not related to AML. Weber stressed that the gap is now closed and we must work together. After his speech, Weber remained in Las Vegas for the entire conference to make himself available for personal discussions with all who were attending and to evangelize about the important work ahead of us.
The high quality product and service offerings from the companies in the exhibition hall was also impressive. While there is no doubt that the economy has impacted business, vendors at the conference were offering a wide range of technologies and services that help us meet the challenges of our profession. Vendors remain a core asset to ACAMS success. The exhibition hall also featured a new booth this year for ACAMS chapters. This provided an opportunity for chapter members to discuss the advantages of joining a chapter with conference attendees.
As co-chair of the Carolinas Chapter, I attended the chapter directors meeting at the conclusion of the conference. Now numbering about 30 chapters worldwide, chapters remain the best opportunity for person-to-person networking.
I also want to note that ACAMS executive vice president John Byrne once again demonstrated that a person does not need to sleep for four days. When not leading a panel discussion or meeting, he could be found in the hallways meeting, greeting and listening to members. John, thank you for your leadership.
In past conferences, I have been a presenter for pre-conference workshops. This year however, I attended the pre-conference CAMS Examination Preparation Seminar (as an observer) for people who were studying for the exam. The workshop was facilitated by Kevin Sullivan and Don Temple both long time thought leader/members of ACAMS. I was attending in order to be certified as a presenter at future examination workshops. Kevin and Don did an outstanding job presenting the material. Those attending left the workshop with a feeling of confidence. I left the workshop glad that I didn’t have to take the exam again.
As many of you may be aware ACAMS is now offering an advanced audit certification. This new certification was a popular point of discussion by conference attendees. The CAMS-Audit is the first certification of its kind in the AML/CTF and financial crime prevention community. Building on current CAMS expertise, CAMS-Audit is graduate-level training that will equip mid-level and senior management professionals with the essential knowledge that reinforces internal controls and enhances the ability to meet regulatory expectations. Numerous conference attendees were planning on participating in the certification sessions during 2013.
The conference offered more great sessions than any one person could attend — but I did my best. The following are a few “takeaways” from the sessions I was able to attend.
The session on adjusting AML audit procedures to meet regulatory expectations was facilitated by bank representatives and regulators. This important subject-matter session provided attendees with an overview of how AML practice leaders need to stay current and agile to meet the always changing regulations and the procedures to maintain compliance. The following are suggestions from the session:
- Learn from regulatory actions brought against other institutions
- Remain attentive to regulatory changes and points of emphasis
- Maintain good relationships and frequent communication with your control partners (e.g., audit, risk, compliance) and your regulators
- Work hard at the front end of the audit process
- Have a sound risk assessment
As we are all aware, the increase of business in the prepaid industry has been one of the largest growth areas in financial services that have impacted our industry. The session mitigating the risks of third-party payment processors centered on the relationship that exist between prepaid providers and the financial institutions partners. During the session the presenters outlined high-risk areas associated with prepaid business channels. The presenters covered a long list of products and services, which included:
- Ammunition sales
- Credit card schemes
- Credit repair services
- Drug paraphernalia
- Escort services
- Firearms/fireworks sales
- Gambling
- Get rich products
The audit/compliance workshop was a session focusing on the relationship between audit and compliance. The session stressed that communication, a shared vision, trust and respect were key elements to building a successful relationship between the two groups.
Law enforcement and bank representatives facilitated a session on the completion and submission of SARS/STRS, an important topic we need to continually visit. A few key points from the session follow:
- SAR Success: Be clear and concise and prioritize the opening paragraph.
- Structuring SARs: Spend time training your bank team to truly understand what structuring is and then apply the knowledge consistently.
- “It’s the law” brochures or letters are an effective technique to address structuring that can benefit both bank and law enforcement if managed effectively.
- Partnerships work, so proactively engage.
- Understanding the subpoena/seizure warrant process in advance will help speed up fulfillment of the process.
In closing, I encourage all members of ACAMS to do their best to attend an annual conference. Every year new and exciting sessions are added that cover issues and challenges that we are presently addressing. The social aspect of the conference is also important. Business cards are exchanged providing attendees with new contacts to help provide solutions to our everyday dilemmas. ACAMS staff searches the world for the best presenters and thought leaders. The fresh and new viewpoints result in high quality and on target information exchange. The presenting faculty is always available and approachable to discuss individual concerns.
See you all next year and good luck to those members who are completing the CAMS-Audit certification.
