Every year, the Association of Certified Anti-Money Laundering Specialists (ACAMS) recognizes and awards several outstanding members for their contributions to the anti-financial crime industry. This year, ACAMS honored four exceptional individuals and one extraordinary chapter. ACAMS awarded the ACAMS AML Professional of the Year to Stuart Davis, the ACAMS Today Article of the Year to Sanjeev Menon, the ACAMS Al Gillum Volunteer of the Year to Angel Nguyen Swift, the ACAMS Career Leadership to David Clark and the ACAMS Chapter of the Year to the ACAMS Central Ohio Chapter.
ACAMS Today had the opportunity to interview the award winners on their beginnings in the industry, advice they have for those currently in the anti-financial crime field and those looking to enter the field, and the next big trend in the financial crime industry. Congratulations again to all of 2019’s ACAMS award winners!
ACAMS AML Professional of the Year:
Stuart Davis, CAMS
Stuart Davis is global head, financial crimes risk management and group chief anti-money laundering (AML) officer at Scotiabank. Davis is an experienced global executive with 29 years of progressive leadership roles in financial institutions (FIs), including more than 15 years running AML, sanctions and financial crime prevention programs, as well as associated technology. He is a recognized industry thought leader, influencer and a subject-matter expert on AML, having made several appearances on the international stage including the United Nations, Financial Action Task Force plenaries in Europe and Asia, and the Organisation for Economic Co-operation and Development (OECD) in Paris. In addition, Davis currently serves as the chair of the ACAMS Greater Toronto Chapter, chair of the Canadian Bankers Association subcommittee on AML, co-chair of Canada’s Department of Finance’s Advisory Committee on Money Laundering and Terrorist Financing, and a member of the board of governors of Junior Achievement Canada, Central Ontario branch.
ACAMS Today: Congratulations on winning the AML Professional of the Year Award! What inspired you to enter the financial crime prevention industry?
Stuart Davis: Much of my early career was spent working on ensuring financial stability through compliance in both the public and private sectors. The eventual transition into financial crimes risk mitigation felt like a natural progression, both in terms of my own personal interest and the way the industry was evolving, placing more of an emphasis on AML and counter-terrorist financing (CTF).
Also, like many whose careers started to take form around the new millennium, September 11, 2001, was a real defining moment for me. It is an event none of us will ever forget and, for me, it really gave a great deal of purpose to the work undertaken in my professional life. This tragic event served as a catalyst and inspired me to focus more on the financial crimes aspect of compliance as the reverberations of inaction were too much to ignore.
AT: At the ACAMS Vegas conference, you were a speaker on a panel about solving financial crime with advanced analytics and intelligence. What are some best practices for using advanced analytics and intelligence in this industry?
SD: Advanced analytics and intelligence are nothing new to our industry, but I believe that their greatest impact has yet to be fully realized. The industry’s technology keeps evolving at a rapid pace to allow for more and more capabilities. However, this rapid evolution also presents the challenge of balancing a program’s budgets and their technological toolkit. A best practice is focusing on what works and what yields the most effective results without being distracted by the bells and whistles. For example, your dollar may be better spent on tuning your sanctions system than deploying a machine learning overlay on your alerts.
AT: You also recently co-wrote an article on digital identity for the September-November 2019 issue of ACAMS Today. What are the benefits and risks of this technology?
SD: Digital identity has seemingly limitless potential across many sectors within the financial services industry and especially within financial crimes risk management. The enhanced ability to store, recall, audit and track customer information within a digital identity network could see significant risk mitigation improvements leveraged by major FIs. However, aside from what the technology could solve in the future, it is important that financial crime professionals be included in the building stages. This means having feedback and input from professions within fraud, cyber, corporate security and AML early on so that the final tool operates at its full potential. Early engagement will ensure that digital identity tools incorporate the appropriate compliance monitoring and framework to help mitigate their use in facilitating financial crimes. This was recently witnessed in the role Estonia’s digital identity network played within the Danske Bank money laundering scheme.
AT: What is the next big trend in the financial crime prevention industry?
SD: The topic of digital identity and its relation to financial crime risk management will continue to be a major discussion area into 2020 and beyond. In addition, the conversation around how FIs approach responsible and effective information sharing with their industry peers and public agencies will also continue to be explored as an effective tool toward dismantling transnational money laundering operations. Lastly, concerted efforts undertaken by the financial services industry to mitigate modern slavery activity—specifically the actions undertaken by human traffickers—will continue to be a major focal point. This is highlighted by the recent publication of the Liechtenstein Initiative’s “A Blueprint for Mobilizing Finance Against Slavery and Trafficking,” as well as the work of the Financial Sector Commission on Modern Slavery and Human Trafficking.
ACAMS Today Article of the Year:
Sanjeev Menon has been a senior manager at Infinity Consulting Solutions since 2008. He is an expert at providing staffing and workforce solutions to clients that are actively creating best-in-class compliance and financial crimes programs in the financial services, fintech, telecommunications, pharmaceuticals and health services industries. Menon has helped clients deal with consent orders and enforcement actions by providing both executive recruitment and contingent labor for projects. He is a certified staffing professional who knows the latest human resources and staffing trends.
In addition, Menon is a regular contributor of the Career Guidance column for ACAMS Today. His column features articles on networking, self-employment, advancement, interviews, resume tips and more.
ACAMS Today: Congratulations on winning the ACAMS Today Article of the Year Award! Speaking of your article, The Networking Mindset, did you have an opportunity to apply any of the tips you gave in this award-winning piece during the ACAMS 18th Annual AML & Financial Crime Conference? If so, which ones?
Sanjeev Menon: Yes. Going into this conference I had already cultivated and established what I consider best practices and that is what encouraged me to write this article. It was based on my experience, the experience of my colleagues and the experience of other people considered to be successful. Based on the situation at a given moment and the nature of a conference, I know which practices to apply. Hopefully, those who read this article were able to do so as well—successfully. The conference was a great opportunity to apply what I share in this article.
AT: Where do you receive your inspiration to write?
SM: It is amazing that I have been a part of the editorial committee and the regular contributor for ACAMS Today’s Career Guidance column—I consider it a privilege. I always keep in mind that I am not a compliance professional who works daily in maintaining compliance. I am in the AML compliance community as a recruiter and a career guidance expert, so I make sure my topics are about that. Helping people create a great career and enjoy their job is what I like to do. I also make sure that I write about topics that are relevant. I confirm relevance from the conversations that I am having every day as a recruiter. When I start noticing trends or commonalities in the topics that I hear from candidates, I become inspired to write my next article.
AT: How do you go about selecting your next article topic?
SM: When I hear a lot of people talking about topics like artificial intelligence (AI) or recessions, I begin to think of the different ways in which I can put together all the information I gather from different sources into a concise and insightful article. One that can provide insightful food for thought and that would include my opinion and those opinions that I gather from my conversations as well. Ultimately, these conversations are my inspiration because there is an exchange of information from both sides, the questions that the candidates have and the answers that the experts in the field provide.
AT: What do you think is the next big trend in the financial crime prevention industry?
SM: Great question. I can share a couple. The first one is the market. People are confused about the employment rate. A lot of people are getting jobs, but there are others who tell me that they are qualified and yet cannot get a full-time job or a contract and that is an issue. The second trend is technology—how is this going to affect the market at a macro level? Will it take away jobs? How can one become more tech-savvy in order to become more attractive to future employers and find more fulfillment in a career? The final changing trend is people. Professionals are embracing a more flexible schedule as opposed to the conventional full-time job. People of all ages are embracing consultancies due to the flexibility in schedule that they offer.
ACAMS Al Gillum Volunteer of the Year:
Angel Nguyen Swift, CAMS
Angel Nguyen Swift is the vice president of compliance and financial crimes solutions at Enigma, a data and technology company headquartered in New York City, where she leads strategic initiatives focused on bringing augmented intelligence to help financial crime professionals effectively make informed decisions.
Prior to Enigma, Nguyen Swift spent nearly a decade building and leading the financial intelligence unit (FIU) at American Express. She was responsible for establishing and maintaining an end-to-end program that supported the suspicious activity reporting process from transaction monitoring rule development to quality control, sanctions screening and investigations, enhanced due diligence reviews, know your customer refresh, anti-corruption and bribery monitoring, and investigation and special investigations.
Prior to American Express, Nguyen Swift served as a New York County Assistant District Attorney (NYCDA) where she prosecuted a wide range of cases. While she was an NYCDA, she served as a charter member of the identity theft and cybercrime unit where she focused on long-term investigations and helped establish protocols for digital evidence in all cases.
Nguyen Swift remains active in the industry by speaking at global conferences, facilitating AML certification courses and participating in public-private working groups. Most recently, she has led a joint effort with ACAMS and Polaris called Stand Together Against Trafficking (STAT), which utilizes data technology to empower the sharing of financial indicators across the financial crime industry with the aim of eradicating human trafficking.
She also currently serves as a board member of the nonprofit organization Polaris and the ACAMS New York Chapter.
ACAMS Today: Congratulations on winning the ACAMS Al Gillum Volunteer of the Year Award! What motivates you to share your time and knowledge with others in the anti-financial crime community?
Angel Nguyen Swift: There are three fundamental beliefs for which I have tried to hold myself accountable. First, focus on people. People drive impact and success. Second, continue to learn. Growth only happens when you feed your mind and soul. To me, this is a multi-pronged approach that includes having natural curiosity, having an open mind and open heart to see multiple perspectives and finding ways to share and discuss what you’ve learned to add value and continue the learning process. Third, do more. I think there is always more you can do, especially if the end goal is to simply do good. The anti-financial crime/anti-money laundering (AFC/AML) community—which I am honored and proud to be a part of—allows me to meet all these requirements in spades. The people are dedicated and passionate about what they do and they have a real genuine desire to learn so they can collectively move toward the larger goal of doing good.
If I can contribute just a little bit to this community and bring something valuable to help people fulfill their own missions in this space, I feel like I have succeeded.
I have recently found inspiration in this quote from Margaret Mead: “Never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it’s the only thing that ever has.”
AT: Between Project STAT and your work at ACAMS events, you are an important advocate for human trafficking awareness and prevention.
What have been some of your success stories in this field?
ANS: In terms of success stories across the industry, I think it happens every day. Making human trafficking awareness and prevention a priority and giving people the time and resources to focus on finding solutions is a huge win thanks to organizations like ACAMS. The fact that the anti-human trafficking movement within the financial industry now consists of a community that includes more organizations, and therefore a wider perspective, is an even bigger win. Our community now includes nonprofit organizations, law enforcement organizations, policymakers and technology companies. Collaboration is the most powerful weapon we have in this fight. We have seen outcomes from the organized takedowns surrounding sporting events like the Super Bowl; these involve coordinated initiatives led by FIs, law enforcement and nonprofit organizations. Another example is the work that was done with Project Protect in Canada. Finally, and most recently, I have seen organized tech sprints that focus specifically on anti-human trafficking solutions for the financial industry.
Win, win, win!
As it relates to STAT, the biggest success we had was when a survivor looked at the indicators we were mapping into the platform and felt, in some way, vindicated. The survivor’s sentiment was that if law enforcement and banks had the information we were seeking to share on the platform 20 years ago, the survivor’s life would be totally different and the trafficker could have been brought to justice much faster. Because STAT represents the work done by this entire industry and will continue to grow with and for our industry, this is a huge success to every single person who has shared something they’ve learned in a working group, at a conference, with a colleague.
We are on the right track, team!
On a personal level, the fact that I have been given the opportunity to triple down on my focus in this space is a huge win. I realize that I am incredibly fortunate to be in a position where I have the support from the industry to be able to actually do the work. Nothing brings me more joy than seeing the hope and empowerment that collaboration brings.
AT: You have had success in both the public and private industry. What advice do you have for professionals looking to make the switch from one to the other?
ANS: Talk to as many people as possible. Ask for different perspectives on roles that sound interesting to you. Networking is incredibly valuable. It is amazing to me the number of people who “fell” into an AFC/AML role because it was unexpected or unknown to them—myself included! Do not be afraid of technology. It is here and it will only become more prevalent in our industry—embrace it. If you do not like or find it to be overwhelming, find someone that does like it and ask them to break it down for you. There are a lot of people who are so passionate about it and in asking them to teach you, you are doing them a favor by giving them practice in explaining these much needed concepts for our community. Spell check your resume and cover letter. Mistakes and typos can be distracting. One of my pet peeves is spelling the USA PATRIOT Act—know which part is an acronym and which is not.
Now for the mushy, but real stuff. Do not limit yourself. I am often asked about the skillset and experience needed to make the switch one way or the other. While these things are important, I think sometimes people get lost in the weeds. It is less about the line-by-line requirements and more about the reason behind a position or role. Skills and experiences can be transferable, and often are, but intent and purpose must align for ultimate success. Trust in yourself so you can advocate for yourself. This also means being completely honest with yourself. Keep calm, be open-minded and most importantly, never, ever stop caring.
There was a concept I was taught a long time ago and I still hold it close to heart: everyone has a super power. As a person, figure out yours. As a leader or manager, help others find theirs.
AT: What is the next big trend in the financial crime prevention industry?
ANS: The next big push will be doing a lot more around coordinated shared resources (people, intelligence and knowledge) across the industry. With the rise of fintechs and a pressure for institutions to be nimbler to respond to customer’s demand, AFC/AML organizations need to be ready to act fast and act effectively. What better way to accomplish this than to combine our efforts, create more consistency, be able to identify threats and collectively learn. We are already doing this in some way on an ad hoc basis—between and among FIs, law enforcement, government and technology.
ACAMS Career Leadership Award:
David Clark, CAMS
David Clark, CAMS is the global head of FCC professional excellence, group financial crime compliance for Standard Chartered Bank. His role encompasses FCC learning and FCC surveillance process. Clark has extensive experience in global financial crime risk mitigation within banks and, previously, government customs agencies. Clark joined Standard Chartered from GE Capital where he headed up the financial crime risk- management function for Europe, the Middle East and Africa as well as the Asia-Pacific region and focused on AML, sanctions and international trade controls, and anti-bribery and corruption. Prior to his position at GE Capital, Clark worked for Barclays Wealth where he held a global role as the head of financial crime intelligence with specific responsibilities for anti-bribery and corruption, politically exposed persons (PEPs), enhanced due diligence and reputational risk escalations. Prior to joining Barclays, Clark worked for ABN AMRO where he held a senior position on their global advisory and analysis team, with specific responsibilities for global AML training and communication and Asia advisory. Before switching careers to work in financial services, Clark had a 16-year law enforcement career as a financial investigator and intelligence officer, which included seven years seconded to a crown dependent territory.
ACAMS Today: Congratulations on winning the ACAMS Career Leadership Award! You have had an extensive and successful career in both the public and private sectors; what has been the key to your continued success in the financial crime prevention industry?
David Clark: Since pivoting my career to the private sector, I have been very fortunate to be supported throughout by an array of dedicated financial crime prevention professionals. They have ranged from inspirational line managers and mentors, helpful peers, and hardworking, high-performing teams, all of whom it has been a privilege to lead. The other constant has been my long-suffering spouse who has tolerated the global traveling nature and work-life integration challenges of the roles that I have taken.
AT: What is the best advice you have received from a mentor or mentors during your career?
DC: “Strong people stand up for themselves, but stronger people stand up for others.” There are two aspects to this:
- As a leader, your staff will grow quicker if you are able to create a safe environment for them to make decisions and sometimes make genuine mistakes from which they will then learn.
- As a calculated risk-taker yourself, it is important to know who in your firm has your back, so building a network of trusted partners and stakeholders is key.
AT: How has the financial crime risk management industry changed since you began your career?
DC: There are too numerous aspects to list, but I will highlight three:
- We no longer just think of AML and CTF in our profession as sanctions, anti-bribery and corruption are now mainstream parts of our roles.
- The rise of regulatory enforcement actions both in number and in size of fines. This has led to the development of more effective financial crime risk management programs in FIs as well as growth in the number of financial crime compliance staff those FIs need.
- The rise in the importance of regtech and the need for financial crime compliance staff to develop digital and data analytic skillsets. This means it is more important than ever for financial crime compliance professionals to invest in themselves by taking time to learn continuously.
AT: What is the next big trend in the financial crime prevention industry?
DC: With so many environment factors and variables, it is difficult to predict, so perhaps it is easier to say what I think will stay constant. Technology may help us with the process aspects of our roles and help us with the increasing volumes of transactions and data, but there will always be a place for well-trained, experienced financial crime compliance professionals who will be required to take a risk-based approach to decisions. Those decisions will help protect their FIs and help fight financial crime whilst still facilitating legitimate financial services.
N.B. The above is my personal view and response.
ACAMS Chapter of the Year Award:
ACAMS Central Ohio Chapter
The ACAMS Central Ohio Chapter was created to service financial crime prevention professionals in the Central Ohio and surrounding areas. Its executive board has representation from a diverse cross section of financial industry professionals in the Central Ohio, Cincinnati and surrounding areas. The chapter provides education, networking and career development for ACAMS members in this service area. In addition, the chapter provides support to its members and the community through networking opportunities and bringing together people from a vast array of relevant disciplines and experiences. The events planned by the chapter bring industry experts, members of law enforcement, the community and academia to promote further development in the industry. Events also provide continuing education and credits for ACAMS members wishing to maintain their Certified Anti-Money Laundering Specialist (CAMS) designation. The chapter helps professionals keep their skills up to date in the ever-changing financial crime prevention environment. Central Ohio Chapter co-chair Jennifer Morrison, CAMS answered the following questions on behalf of the chapter.
ACAMS Today: First of all, congratulations on winning the Chapter of the Year Award! What are some of the positive changes the Central Ohio Chapter is proud to have accomplished this year?
Jennifer Morrison: On behalf of our chapter, thank you very much for the award! We could not have achieved this without the efforts of the entire board. From the beginning in the fall of 2017, we committed ourselves to offering meetings focused on high-impact, high-interest subjects featuring experts that will educate our members. This past year, we celebrated our chapter’s first birthday in November 2018 by covering the cannabis business in Ohio (a newly minted medical marijuana state) with a panel discussion, including a local academic expert on money services businesses and a member of law enforcement, along with Ohio’s credit union league’s legal counsel. We covered human trafficking at our February meeting, featuring the U.S. Bank team who had put together an interdiction program implemented at a prior Super Bowl. In May, we were hosted by Huntington Bank and we featured a panel on elder and vulnerable adult financial abuse, including federal law enforcement agents who spoke on suspicious activity report (SAR) narratives and typologies. At our August meeting hosted by Nationwide, we had an ACAMS expert on cryptocurrency and members of a federal task force speak on the use of virtual currencies as a form of illicit finance. Our annual meeting on November 13 featured a panel of law enforcement who discussed how to write strong and actionable SARs.
AT: Could you share some of the strategies that have led to a successful chapter?
JM: It takes a lot of hard work and a lot of dedication on the part of a highly engaged board. We owe much to our true founder, Roseanna Ridgway, and to the mentorship from the Northern Ohio board. Ridgway assembled a group of passionate leaders who have really coalesced around making this a vibrant organization. We are also fortunate to have several large banks and credit card issuers that have placed their FIUs in Central Ohio. We worked hard at the onset to engage these FIs and to bring their leaders to our board. I think one idea we instituted early on was surveying our members after our events, including consistently asking our members about the “hot topics” they want to hear. We also think two to three events ahead and have a plan about which topics we want to cover over the course of the next 12 months.
AT: What does the Central Ohio Chapter have in store for its members in 2020?
JM: We had a great celebration for our “birthday” in November and we already have our February meeting date and location set. We hope to be covering customer due diligence (not beneficial ownership), sanctions and PEPs in 2020.
AT: What do you think is the next big trend in the financial crime prevention industry?
JM: In my opinion, the increasing role of AI in the industry is a hot topic. Due to the fact that much of the routine account and customer monitoring can be accomplished through machine learning, FIs will continue to see the efficiencies and cost savings of AI. I believe there will always be a role for humans—there is so much of a “gut” feeling involved in AML, not to mention there is still human interaction at branches. I just moderated a webinar for ACAMS on SAR writing and one of the federal law enforcement panelists pointed out that there is an increasing call for SARs to include the observations made by the FI’s staff on the subject of the SAR (e.g., if a client seemed nervous at the time of a financial transaction). White-collar crime cases are hard cases to prosecute and law enforcement needs AML professionals now more than ever. This was also made clear when we covered elder financial abuse. Our branch staff is still on the front lines and we can all still make a difference.