Every year, ACAMS recognizes and awards several outstanding members for their contributions to the anti-financial crime (AFC) industry. This year, ACAMS honored four exceptional individuals and one extraordinary chapter at the return of the in-person ACAMS Las Vegas conference. ACAMS awarded the ACAMS AFC Professional of the Year Award to Ahsan Habib; the ACAMS Today Article of the Year Award to Sarah Beth Felix, Lauren Kohr and Angel Nguyen Swift; and the ACAMS Chapter of the Year Award to the Hong Kong Chapter. ACAMS Today spoke with the award winners about career paths, trends in the AFC industry, what inspires them and more.
ACAMS Today chatted with Sarah Beth Felix, Lauren Kohr and Angel Nguyen about their respective writing processes and the next big trend in the AFC industry.
Felix is recognized in the compliance industry for her ability to navigate and operationalize global anti-money laundering/counter-terrorist financing (AML/CTF) regulations to impact various institutional environments and risk profiles. She has almost 20 years of experience in AFC with operational, audit and consulting roles. As a former AML officer, Felix provides actionable, sustainable and effective solutions through remediation projects, system validations, audits and operational strategy. Working with both banks and fintechs, she employs a unique discovery process that highlights risk exposure previously unknown to the institution. She is considered an expert in distilling Financial Action Task Force (FATF), Wolfsberg, European Banking Authority, European Union and Financial Crimes Enforcement Network (FinCEN) guidance into actionable and effective risk-based programs. Felix has niche expertise in operationalizing typologies and money laundering/terrorist financing threats within higher-risk areas, such as cannabis banking, fintechs, correspondent banking and trade finance. She is a highly sought-after speaker with engagements throughout the Caribbean and the Americas.
Kohr’s background includes more than 16 years of experience in the AFC sector with significant experience in Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions compliance, managing complex regulatory issues and remediation projects, and facilitating public and private partnerships to develop effective strategies to combat illicit financial activities. Currently, she serves as the senior director, AML of Americas for ACAMS. As the senior director, Kohr is focused on building the global AFC public-private partnership engagement initiative, assisting in executing the global law enforcement strategy from a thought-leadership perspective, and serving as both a subject-matter and technical expert on AML/CTF, regulatory policy and AML regime priorities.
Nguyen Swift has spent her career operationalizing financial crime compliance programs for FIs, such as American Express and Wells Fargo. Through her foundational training as a prosecutor at the Manhattan District Attorney’s Office, passion for investigations, and dedication to finding frontier technology and data solutions, she is dedicated to effectively transforming how FIs can have a meaningful impact on protecting themselves and the financial system from nefarious actors. Nguyen Swift strongly advocates for the power of collaboration across industries; as such, she has worked with nonprofit organizations, such as Polaris, for which she is a board member, government agencies, law enforcement, banks and technology companies to bring more awareness to how bad actors exploit the financial systems through large networks.
ACAMS Today: Congratulations on winning the ACAMS Today Article of the Year Award! You wrote your article shortly after the onset of COVID-19. How did you determine the appropriate approach when writing about this unique scenario?
Sarah Beth Felix: Zoom chats were our lifeline when things started to shut down. So, on one Zoom happy hour, we were talking about how AML officers were going to be dealing with all of the fallout from COVID-19, the new typologies and an already understaffed area with the potential for a more severe understaffing, given COVID-19 complications. We tried to come up with the most actionable items as information was flowing from every three and five-letter federal law enforcement agency.
Lauren Kohr: As a practitioner at the time, knee-deep in the challenges and impact the pandemic was having on my AML compliance program, team members and resources, I knew I was not alone in the struggle and wanted to share solutions and toolkits to address the challenges practitioners and I faced globally. I was genuinely grateful for the opportunity to partner with two other global experts in the AML compliance space to enhance the best steps to take in this unique scenario when writing this article.
Angel Nguyen Swift: We were all going through what felt like an endless period of so many unknowns. And we were all in it together. We wanted to provide some help to our anti-money laundering/anti-financial crime (AML/AFC) community so people could be as prepared as possible to ensure their programs could remain effective. Business continuity plans (BCPs) for AML/AFC programs are typically rolled up into a companywide BCP, for which planning is at a high level. There are specific considerations for an AML/AFC program that are not often detailed. As we saw at the onset of COVID-19 last year, so many people were trying to pave the road while driving. We thought it would be helpful to take some of that paving away.
We live in information overload, and I want to make sure that what I contribute impacts the operational day-to-day for AML practitioners
AT: You have all previously written several articles for ACAMS Today. What inspires you to write, and could you share your writing process?
SBF: As a former AML officer, my goal in anything I do—whether it is writing or speaking—is to provide relatable and digestible information. We live in information overload, and I want to make sure that what I contribute impacts the operational day-to-day for AML practitioners. It is not good enough to just opine on the state of things or the future state of things. Clear, actionable steps and assistance with establishing effective perspectives of emerging issues are what inspire me.
LK: When I identify a need, such as AML compliance program areas to evaluate in light of a global pandemic, I am inspired by the opportunity to provide our membership and the broader industry with solutions to challenges and problems. I strive to focus my writing content on detailed, actionable and operationalized solutions to the challenges discussed, hoping it will make AFC programs more effective.
ANS: There is nothing I believe in more than the power of collaboration to fight financial crime. That means sharing things that I’ve learned throughout my experience, bringing awareness to current and emerging issues, and opening the dialogue to tough conversations we must have as a community. ACAMS Today provides the platform, support and audience to do all of those things. I am constantly learning—from my experiences, my colleagues, my family and friends. I hope it will make me a better person—personally and professionally—and ultimately, best situated to collaborate with our AML/AFC community.
There is nothing I believe in more than the power of collaboration to fight financial crime
AT: What topics are top of mind to the ACAMS Today readership?
SBF: The Anti-Money Laundering Act of 2020 (AMLA) would most likely be the biggest topic. Most institutions are not sure what to do with all of the changes and given the lack of guidance from regulatory agencies, many institutions will not be well prepared.
LK: In the U.S., I think what is top of mind to our readers in FIs is understanding how AMLA, Corporate Transparency Act, U.S. national priorities, advanced notice of proposed rulemaking on AML program effectiveness and several other legislative initiatives will ultimately impact compliance programs and what a practitioner should be doing right now.
ANS: Technology remains top of mind for me—how we can best leverage the right technology to do our jobs more effectively. Everything from collecting and handling data, to screening, to investigations, to reporting and insights into operational intelligence. A few others include cryptocurrency, information sharing and staying close in emerging crimes. One of my goals is to ensure that everyone working in the AML/AFC space fully understands what human trafficking is and how our financial systems are used to perpetuate the business.
AT: What is the next big trend in the AFC industry?
SBF: As the AMLA is rolled out and effective dates are provided, the biggest trend in the AFC community will most likely be tied to the national priorities. These priorities are not limited to the U.S., as they highlight global trends in financial crime. With the focus on priorities, the global AFC community will now be required to shift away from the check-the-box mentality and into an effectiveness focus. Shifting the focus to effectiveness is the only way to address priorities and related crimes.
LK: The next big trend and a keyword I expect to see the buzz around is “effectiveness” across the industry, and that is seen both in the globally proposed, pending and passed legislation. How effective is the work both the public and private sectors do to combat financial crimes? Effectively detecting and reporting financial crimes tied to, for example, the U.S. national priorities and providing highly useful information to law enforcement is key. In addition, criminal, drug and terrorist organizations continue to evolve the mechanisms and methods they use to move illicit monies. The complexities of their illicit money flow directly intersect with how effective AML compliance programs can detect this activity and the ability of the AFC compliance industry to provide highly useful information to law enforcement. I expect to see globally widespread initiatives from both the public and private sector to transform AML compliance programs from check-the-box programs to more effective monitoring programs focused on providing highly useful information to the public sector.
ANS: It’s already a big trend in the AFC industry, but I think crypto/virtual/digital assets will continue to be a big trend in AFC for the foreseeable future. Another area that should be the next big trend is looking for ways to share information across the financial sector. Between emerging fintechs looking for better ways to provide financial services, the increased customer appetite for digital solutions (only accelerated by COVID-19), and the continued quest to deliver more insights versus data to vastly enhance decision making by both consumers and banks, the ability to share data (or at least data insights) is pivotal.
Interviewed by: Karla Monterrosa-Yancey, CAMS, editor-in-chief, ACAMS, FL, USA, firstname.lastname@example.org
Stephanie Trejos, CAMS, editor, ACAMS, TX, USA, email@example.com