ACAMS Today is kicking off the celebration of ACAMS’ 20-year anniversary with a list of the 20 most transformative anti-financial crime (AFC) events of the last 20 years. The editorial team asked ACAMS advisory board co-chair Rick Small, CAMS, and former ACAMS advisory board member Lauren Kohr, CAMS-FCI, for their input.
Small leads the financial crimes team for Truist, which includes managing anti-money laundering (AML) compliance, controls and investigations, fraud management and the financial investigations resulting from cyber events. He joined BB&T, now Truist, in 2016 as the first financial crimes program director.
Small has over 35 years of experience in the public and private sectors. Before joining BB&T, he was the senior advisor for AML and financial crimes with EY; senior vice president, enterprise-wide AML, anti-corruption and international regulatory compliance for American Express; and the AML leader for GE Money, a division of General Electric. Small began his private sector career as managing director, global AML for Citigroup.
Prior to these private sector roles, he held several positions with the U.S. government, first as a federal prosecutor with the U.S. Justice Department in the Antitrust Division and then with the Organized Crime Strike Force, followed by the senior counsel for law enforcement at the U.S. Treasury Department. His most recent government position was on the staff of the board of governors of the Federal Reserve System as deputy associate director in the Division of Supervision and Regulation.
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 Anti-Financial Crime Task Force focused on public-private partnership engagement, assisting in executing the global law enforcement strategy, and serving as both a subject-matter and technical expert on anti-money laundering/counter-terrorist financing (AML/CTF), regulatory policy and AML regime priorities. Previously, she served as the senior vice president, chief risk officer and BSA officer at Old Dominion National Bank (ODNB) in Tysons Corner, Virginia. In this role, Kohr was responsible for ODNB’s enterprise risk management program, including leading the bank’s BSA/AML and Office of Foreign Assets Control (OFAC) program.
Before her role at ODNB, Kohr served as the vice president/director of AML/BSA/OFAC at Metro Bank in Harrisburg, Pennsylvania. During this time, she was responsible for developing, implementing and overseeing all aspects of the Bank Secrecy Act (BSA) compliance program, including the USA PATRIOT Act, AML and OFAC regulations. Kohr was the 2016 ACAMS AML Professional of the Year, won the 2016 ACAMS Today Article of the Year Award and was awarded the U.S. Capital Excellence in Public/Private Partnerships in 2019. She is a frequent speaker at numerous conferences, both domestically and internationally, for the public and private sectors on AML, BSA, OFAC and counter-terrorist financing (CTF)-related topics. Kohr serves on the ACAMS U.S. Capital Chapter board of directors, AML Partnership Forum board of directors and is part of the Empowering Together: Women in AML initiative. She also previously served on the ACAMS advisory board.
As subject-matter experts in their respective fields and as well-known orators in the AFC space, Small and Kohr shared with ACAMS Today what they thought were the top 20 most significant AFC developments over the past two decades. During the discussion Small and Kohr mentioned similar items on their list. ACAMS Today took their valuable input and combined their lists to bring you the top 20 most transformative items in the past 20 years:
- September 11, 2001
- USA PATRIOT Act
- The Federal Financial Institutions Examination Council BSA/AML Examination Manual
- Enhanced private-public partnerships
- Financial institution industry engagement with combating human trafficking and assisting human trafficking survivors
- Broad expansion of AML to include CTF
- Broad expansion of AML to include cybercrime
- Broad expansion of AML to include fraud
- Financial institution industry engagement with not-for-profits to provide guidance and banking services for nongovernmental organizations and nonprofit organizations
- Customer due diligence regulation
- Beneficial ownership requirements
- Anti-Money Laundering Act of 2020
- Release of the first-ever AML national priorities
- The rise of fintechs as an alternative to traditional banks to provide banking-related services
- Digital currencies to include cryptocurrency, virtual currency and informal value transfer systems
- AML technology to include big data, artificial intelligence, machine learning and automated transaction monitoring systems
- Identification of money flow tied to social impact issues, such as environmental crime
- Trade-based money laundering
- The complexity of sanctions evasion schemes
- COVID-19 pandemic
Finally, both Small and Kohr shared their thoughts on what the next 20 years could hold for the AFC industry. Small stated the following, “In the next 20 years, I would expect that emerging technology is going to significantly blossom and provide cutting edge technology solutions to manage AML risks.”
Kohr added, “In the next 20 years the focus will be to:
- Continue to find more effective and innovative ways to combat money laundering, terrorist financing and proliferation financing
- Evolve public-private partnerships and opportunities to share information
- Position the AFC community to be both proactive and reactive in combating these heinous crimes
- Go above and beyond, do more than our part, expand our thinking beyond the norm
We all must play our part and find ways to evolve the AFC community and its initiatives; and not find reasons why we can’t or let barriers and challenges prevent us from trying. We can do it.”
As we begin the 20-year celebration of ACAMS, we also want to remember and honor the 2,977 people who lost their lives on 9/11 during the most horrific terrorist attacks on American soil. In addition, we would like to remember and thank the dedicated first responders who ran toward danger to save their fellowmen on that fateful day.
ACAMS Today is grateful to be a part of a community and industry that is fighting to end financial crime and everything it encompasses. We hope you will join us as we continue celebrating 20 years of ACAMS from now and into 2022.