MAY/JUNE 2005VOL. 4 NO. 3

Official newsletterof the Associationof Certified Anti-Money LaunderingSpecialists

www.acams.org

ACAMSTODAYAdvancing the professional knowledge of

those dedicated to the detection and prevention of international money laundering

A Look at theJob Outlook for

AMLFrank Hannah wasn’t even looking for a job

when he found one. His bank was acquired bya larger one, with lots of opportunities formobility. “I was contacted by a colleague whosaid, ‘We really need to get our anti-moneylaundering (AML) processes beefed up. Areyou interested?’”

It was that simple. While this definitelyspeaks to the value of networking, there’s anoth-er factor of Frank’s story to consider: “Prior togetting this call I would get three calls a monthfrom headhunters looking for AML officers,” hesays. So how typical is Frank’s story? And justhow hot is the AML job market right now?

So what is the current state of AML hiring?Well, while hard numbers aren’t available toprovide a clear-cut outlook, it is possible toget a sense of what it’s like out there.Recruiters specializing in the financial servi-ces industry talk to employers every day andfind out firsthand what their AML needs are.In addition, we were also able to speak toBetty Jo Zbrzeznj, director of the AML officefor Wachovia, who discussed with us thebank’s efforts to expand this department overthe past few years.

Through this, we were able to shed at leastsome light on certain key aspects of the hiringoutlook in AML.

Perspectives on Demand Recruiters seem to be quite optimistic

about demand in the field. “Anti-money laun-dering positions are hot, particularly candi-dates with knowledge of Bank Secrecy Act(BSA) and/or USA Patriot Act responsibili-ties,” says Brendan Cruickshank, head ofsales for jobsinthemoney.com, an employmentwebsite for financial professionals. LenAdams, CPC, the CEO of Adams ConsultingGroup, a recruiting firm based in New York,agrees, describing the market as “verystrong.” In 2001, Adams rarely received callsfrom employers looking for AML profession-als, perhaps one every few months. He nowaverages two to three calls per week.

For its part, Wachovia has doubled its AMLstaff compared to three years ago. Zbrzeznjcites a couple of factors behind these num-bers, such as “Wachovia’s

“We don’t yet have a nuanced portrait of the AML job market.”Determining Demand Is a Challenge

This is actually a tough question to answer,basically because AML is a relatively youngfield. The fact is, up to this point, no one hasconducted an industrywide study focused onhiring trends in the field. The U.S. Bureau ofLabor Statistics offers no employment projec-tion for AML specialists, and internationallyno studies of the profession’s hiring outlookare available.

Employers could offer some answers, butit’s not easy to obtain them. Staffing informa-tion is not something that is readily dis-closed. With banks, obviously the biggestemployer in AML, this could be because AMLcompliance staff numbers are embedded inoverall compliance numbers and, therefore,are not easy to ascertain. Also, there is specu-lation by some that banks are concernedabout being second-guessed as to whetheradequate resources are being deployed andare therefore reluctant to discuss specificnumbers. And with government agencies,internal policies generally prohibit them fromoffering specifics on the topic of hiring trendsin certain areas. (continued on p. 8)

INSIDE2 AML Briefs

3 A Tightened AML Regime in Switzerland

4 Member Spotlight

5 The EU Gets Tough on Financial Crime

6 The Art of Smart Salary Negotiation

7 In Your Words

8 Mark These Dates

10 People NewsTips for Training Financial Investigators

www.acams.org/espanol

ACAMSTODAY

2 | ACAMS TODAY MAY/JUNE 2005

A WORD FROMAN ADVISORYBOARD MEMBER

As we enter late spring andearly summer, the insurance indus-try is anticipating the U.S. TreasuryDepartment’s release of the USAPatriot Act regulations for productproviders: the basic Anti-MoneyLaundering Program and SuspiciousActivity Reporting guidelines willpossibly bloom this May.

Once the final regulations arepublished, the insurance industrywill have anywhere from 90 days to6 months to establish proper com-pliance programs, as well as poli-cies, procedures and controls forreporting suspicious activity.

Although the TreasuryDepartment has stated that out-reach and education will be provid-ed to the industry, many ACAMSmembers are already on their wayto implementing the necessary pro-cedures for their company’s pro-grams. Many of these are based onthe extensive information, guidanceand training that ACAMS offers toassist anti-money laundering spe-cialists with the detection and pre-vention of money laundering.

I encourage you as an ACAMSmember to utilize the tools it pro-vides, and as you continue to for-mulate your programs, look foropportunities to participate in webseminars or share your ideas andinquiries on the ACAMS Listserv.Remember that your fellow ACAMSmembers in the financial industryhave already been through the ini-tial process and can assist you inmaking your program flower.

Regards,

L. Kim EstradaAVP-Compliance OfficerWestern Reserve Life AssuranceCo. of Ohio St. Petersburg, Florida, U.S.

A M L B R I E F S

Prison Term for a Laundering Lawyer in Canada

A lawyer who bragged that he had been“cleaning money” for over a decade will servethree years in prison for money laundering.Toronto attorney Simon Rosenfeld was arrestedin 2002 as part of a joint sting operation conduct-ed by the Royal Canadian Mounted Police(RCMP) and the United States’ Federal Bureau ofInvestigation. The sting, called Bermuda Shortand focused on stock price manipulation andmoney laundering schemes, netted 50 other peo-ple besides Rosenfeld.

RCMP undercover operative Bill Majcherposed as member of a Colombian drug cartel thatsupposedly was looking to launder millions ofdollars. Majcher met several times withRosenfeld, secretly recording conversations inwhich the attorney boasted about his moneylaundering experience and the offshore accountshe had been operating for over 20 years. He alsomentioned his organized crime contacts and saidhe had previously lied under oath.

According to the Toronto Globe and Mail,Rosenfeld claimed to earn $3 million Canadiandollars per year but reported only $25,000 peryear for taxes. The newspaper further reportedthat prosecuting attorney Rosemary Warren askedfor a seven-year sentence, arguing that lawyersare key in money laundering and a stiff sentencewould serve as a deterrent. But Madam JusticeTamarin Dunnet stated that due to sentencingguidelines established in other money launderingcases, three years was appropriate.

Myanmar Closes Two Banks for Breaking Laws

Myanmar, one of the three countries left onthe Financial Action Task Force’s list of non-cooperative countries, has shut down two privatebanks for violating the country’s banking laws.

The Associated Press reported that Myanmar’sMinistry of Finance and Revenue revoked thelicenses of Asia Wealth Bank and MyanmarMayflower bank on March 31. A representativefrom the Ministry made the announcement onstate television, saying, “It was found that thesetwo banks have not strictly followed the bankingregulations.” However, the Ministry did not spec-ify exactly what the banks did—or did not do—with regard to banking regulations, nor whichregulations were not followed.

The United States State Department hasaccused both of these particular banks of laun-dering money and of having ties with SoutheastAsian drug traffickers.

In addition, in December 2003 the Myanmargovernment announced that it had been investi-gating these two banks with regard to the coun-try’s anti-money laundering laws, which at thatpoint had only just come into effect. The investi-gation was to have lasted three months, and thebanks could have had their assets frozen if foundguilty of laundering. But no results of that inves-tigation were ever made public. The Ministry ofFinance and Revenue’s announcement did notaddress whether the closures were related to thisprevious investigation. Central bank administra-tors will take over operations at both banks.

ACAMSChairman: Daniel Soto, CAMSExecutive Director:Saskia Rietbroek-Garces, CAMS, MBAProgram & Training Manager:Efraín Venezuela, MS, Ed.D.Member Services: Patricia PaizWeb Development: Diego SanzMembership Coordinator: Perla OrtizEditorial and Communications Manager: Abel Delgado

ACAMS ADVISORY BOARDChair: Daniel Soto, CAMS, Anti-Money Laundering ComplianceExecutive, Bank of America, United StatesHussam A. Al-Abed, AML Consultant, JordanMary Bhawnani, Senior Vice President-AML Relationship Manager,ABN AMRO Bank, United KingdomNina Boteva, CAMS, Partner, Boteva & Kantutis, BulgariaJohn J. Byrne, Director of the Center for Regulatory Compliance,American Bankers Association, United StatesGarry Clement, CAMS, Chief of Police, Cobourg, CanadaL. Kim Estrada, CAMS, AVP-Compliance Officer, Western ReserveLife Assurance Co. of Ohio, United StatesAl Gillum, CAMS, Postal Inspector (Ret.), United StatesJorge Guerrero, CAMS, President, Optima Compliance andConsulting, United StatesCharles A. Intriago, President, Alert Global Media, Inc., United StatesMichael R. McDonald, CAMS, AML Consultant, McDonald &Associates, Inc., United States

James Richards, Global AML Operations Executive, ComplianceRisk Management, Bank of America, United StatesNancy Saur, CAMS, MICA, Compliance Officer, Bodden CorporateServices Ltd., Cayman IslandsRichard Small, Director of Global Anti-Money Laundering,Citigroup, Inc., United StatesPatricia Torres, CAMS, Senior Manager of FinancialIntelligence, Mancera, Ernst & Young, MexicoJos de Wit, CAMS, AML Consultant, The Netherlands

ACAMS Today is designed to provide accurate and authoritativeinformation concerning international money laundering controlsand related subjects. In publishing this work, neither the authorsnor the association are engaged in rendering legal or other pro-fessional service. The services of a competent professional shouldbe sought if such assistance is required.

ACAMS Today is published six times a year for ACAMS members.

For advertising or membership information, contact us at:The Association of Certified Anti-Money Laundering Specialists (ACAMS)1101 Brickell Avenue, Suite 601-SMiami, FL 33131, USATel. 1-305-373-0020; Fax 1-305-373-7788; E-mail: info@acams.org Website: www.acams.org • www.acams.org/espanol

ACAMSTODAY

6 | ACAMS TODAY MAY/JUNE 2005

W O R K I N G S M A R T E R

You know you nailed the interview—thencame the offer. You accepted. A happy end-ing, right? Not necessarily.

You may well have sold yourself short ina big way, missing out on thousands of dol-lars because you didn’t negotiate. Accordingto salary negotiations coach Jack Chapman,author of Negotiating Your Salary: How toMake $1,000 a Minute, this is a commonmistake that candidates make. He says thattwo other critical mistakes that candidatesmake are “talking about salary first” and“thinking that the job is what it is and itcan’t be any bigger.” So how to avoid thesemistakes? Here’s a look at some basic strate-gies to employ to get the best price for yourservices—and maybe even a big raise beforeyou start your new job.

Doing Your HomeworkYou need a starting point for negotiations,

hard data you can back up if an employerchallenges you. So you need to researchwhat your desired position pays, factoring inexperience level and where you live. Thereare a variety of places to get this informa-tion. Chapman recommends several web-sites, including salary.com,careerjournal.com and payscale.com, whereyou can research salaries for your desiredposition. Some websites will even preparean individualized report for an extra fee.

Now, anti-money laundering may notappear on these sites because it’s so new. Tryto see if you can obtain an individualizedreport and if you can’t, try other sources:scan the job openings posted on the ACAMSjob bank and talk to financial servicesrecruiters, who also may put you on to newjobs opening up.

Also, canvass your contacts: peers withwhom you have a good relationship can giveyou a ballpark salary to work with. In addi-

tion, ACAMS will soon launch the first-everworldwide AML salary survey, an additionalresource that you’ll soon be able to use.

Besides salary, factor in all the benefitsyou want—and which ones you think can benegotiated. Chapman suggests this strategy,and you’ll see why when we get into tactics.

Ultimately, your goal is to establish asalary range and median to give you moreflexibility for negotiation.

Show Me the MoneyOnce you have your range set with hard

data, then you get into the actual negotiationprocess. Here are some tips to handle it fromthe beginning.

Avoid the current salary trap. The expertsall agree that you should not reveal whatyou make when a potential employer asksyou, because that will be the starting pointfor negotiations, not the amount that youresearched. Interviewers ask this question toweed you out in case your answer is toohigh—and to gain a negotiating advantage.So how do you answer this question?Chapman offers several ideas: “Listen, I’d beglad to talk about that, but is this the righttime? Are we in a place where you’re makingan offer?” The potential employer can onlysay “yes” or “no.” You can further throwthem off this question, says Chapman, bysaying: “I’m sure we can get to a good salary.I think we should focus on whether I’m theright fit.” Or you could turn it around: “Ifyou’re asking, it could be because you’reworried about your budget. What kind ofrange did you have in mind?” At that point,they respond and you get a sense of wherethey are. However, do not agree with theirfigure. The experts say that your responseshould be more neutral, as in, “That figureseems to fit within my range.” Then try tosteer the conversation

Getting a RaiseKeys to Smart Salary Negotiation

(continued on p. 11)

Before You Even Start

ACAMSFINGER ONTHE PULSE

How would describe theAML job market thesedays?

Exploding—more opportuni-ties than ever (15) . . . . 44%

Stable—there are jobs outthere, but not an enormous amount (15) . . . . . . . . 44%

Not good—it’s a tight mar-ket and hard to find a goodjob (4) . . . . . . . . . . . . 12%

Total votes: 34

Stay tuned to www.acams.orgfor new polls so you can castyour vote!

ACAMSTODAY

(continued from p. 1)

8 | ACAMS TODAY

MARK THESE DATES

MAY/JUNE 2005

growth during that same period, along withthe heightened regulatory focus on AML.”

But heightened regulations are not the onlydemand driver. Both Zbrzeznj and recruiters sayit comes down to the simple principle of supplyand demand, with a relatively small pool ofexperienced AML professionals out there.According to Adams, “There has been a scarcityof qualified people. This is due to the fact thatthe function itself has really increased over thepast few years. Thus, there is not an abundanceof people that were performing the function as afull-time responsibility.” Cruickshank agrees:“Demand is driven by a lack of qualified candi-dates with the right skills.”

Where the Jobs AreCruickshank says that he sees the most

demand from the banking and financial servi-ces sectors. And while he observes that largerbanks seem to have a greater volume of overalldemand, he notes that “regional and communi-ty banks are also looking for professionals withrelevant experience.” Connie Fenchel, founderand executive recruiter for amlexperts.com, aninternational search firm for AML and BSAindependent consultants that is based inWashington, D.C., and Daytona Beach, Florida,has a different perspective. “Actually, I believethere is a greater demand in non-banking busi-nesses, such as money services businesses(MSBs),” she says. “Banks have been requiredto have AML programs much longer than

MSBs, broker/dealers and the insurance indus-try, so most banks have developed comprehen-sive AML programs. It’s the others who aredesperate for knowledgeable, qualified AMLexperts,” says Fenchel.

What They’re Looking ForSo what are the ingredients to an outstand-

ing AML resume? Adams simply states that hesees employers looking for “3+ years of experi-ence,” while Cruickshank has seen an interestin “candidates with anti-money launderingexperience from all career levels.” For her part,Fenchel has seen the experience required byinstitutions to vary with the position, thoughshe says employers are focused not just ongeneral AML experience but rather on AMLexperience within a particular industry, suchas MSBs or insurance. Zbrzeznj says thatWachovia seeks a variety of experience types,such as former law enforcement officers andformer regulators.

The Emerging ImageWithout question, we don’t yet have a

nuanced portrait of the AML job market, full ofthe exhaustive detail that empirical evidencecan supply. However, the perspectives fromsources involved in hiring do offer a roughsketch, one that suggests clearly that AML is indemand and that experienced professionals inthe field are poised to enjoy more opportunitiesthan ever before. The next step, of course, is astudy, preferably at the international level, thatwill truly allow AML professionals to under-stand their market value and career potential.

May 2ACAMS

CAMS Examination Preparation Seminar (en español)

Cartagena, Colombia

http://www.acams.org/certification/certification_examprep.aspx

May 4-62005 West Coast Anti-Money Laundering Forum

San Francisco, United States

http://www.wcamlforum.org/

May 11The Institute of Money Laundering Prevention Officers

Second Annual Conference

West Midlands, United Kingdom

http://www.imlpo.com/conference/home.shtml

May 18-19Complinet

Complitech 2005

London, United Kingdom

www.complitech.co.uk

May 19-20The Center of Business Intelligence

Insurance, Compliance, Transparency and Ethical Conduct

New York, United States

http://www.acams.org/pdfs/FB552_David%20(2).pdf

May 21ACAMS

CAMS Examination

Amsterdam, Netherlands

http://www.acams.org/certification/certification_examdates.aspx

May 27ACAMS

CAMS Examination Preparation Seminar (en español)

Mexico City, Mexico

http://www.acams.org/certification/certification_examprep.aspx

June 3ACAMS

CAMS Examination Preparation Seminar

Los Angeles, United States

http://www.acams.org/certification/certification_examprep.aspx

June 12-15American Banker’s Association

ABA Regulatory Compliance Conference

Baltimore, United States

http://www.aba.com/Conferences+and+Education/ce_regulatory_com-pliance.htm

June 17ACAMS

CAMS Examination

Cartagena, Colombia

http://www.acams.org/certification/certification_examprep.aspx

June 23ACAMS

Web Seminar

AML Training: Is Your Training Up to Par?

http://www.acams.org/webcasts/series/Webcastseries.aspx#Second

June 25ACAMS

CAMS Examination

Grand Cayman, Cayman Islands

http://www.acams.org/certification/certification_examdates.aspx

ACAMS TODAY | 11MAY/JUNE 2005

back to how you can help the company. Thegoal is to make yourself a prime commodityso that when the conversation turns back tosalary, they’ll want you—and be willing topay big for your services.

Just say “Hmmm.” When the offer doescome, advises Chapman, “use a four-letterword without any vowels that’s not in the dic-tionary but that everybody uses: ‘Hmmm.’ Soif they offer you 50,000, you go “50 thousand …Hmmm … allow for some silence.” That’swhen they’ll ask you if that figure is okay ornot. But don’t answer it.

Or try the echo. Daniel Porot and FrancesBolles Haynes recommend a similar tech-nique in their book, 101 Salary Secrets: “theecho.” It basically means repeating the offerwhile looking the interviewer in the eye,showing only the faintest hint of surprise.Then allow for silence. If a range is men-tioned, you can still use this technique: justecho the highest figure of the range. Salaryconsultants say that either approach couldmake the potential employer think that thisfirst offer is way too low and thus offer anincrease right on the spot.

Table salary discussions once more. Oncethe figure is out there and you’ve “hmmmed”or echoed, Chapman suggests segueing to bene-fits. For example, if a potential employer offersyou $50,000 per year, Chapman recommendssaying: “Before we dig in to that, there are acouple of small things that we should clear outof the way.” That’s when you go for the benefitsthat you feel are most negotiable. For example:“I presume that at this level, if I needed threeweeks vacation rather than two, we’d be allright there, correct?” And you proceed fromthere. “They’re eager at that point to get to thebase salary,” explains Chapman. “That’s yourbest chance of them saying, ‘Okay, that’s fine.Now, what about that 50,000?’”

Even if you don’t get these extra benefits,the refusal can be added leverage. When youget into salary discussions, you can politelybring up the lack of benefits in your argumentfor more money.

Get into range. Once you’re back at salary,your next move depends on what their offeris. It could be at the top of your range, belowthe bottom or just right. Scenarios 1 and 3 aregenerally unlikely, so let’s look at the lowoffer. You counter with your researched range,which you can bracket, suggests Chapman.For instance, if the researched range isUS$45,000 to US$50,000, bracket the range bytelling the potential employer that yourresearched range is US$47,000 to US$50,000.

William Cohen, Ph.D., author of Break theRules: The Secret Code for Finding a Great JobFast and professor of business at Touro

University International, offers another option.He suggests telling the employer that the job isat least worth $X, a figure 10 percent above theemployer’s offer. This is tricky, he explains,and a call you need to make on the spot. Hefeels that it’s unlikely that an employer willeliminate you from contention just becauseyou asked for 10 percent more.

Don’t do it over the phone. If the employ-er calls you with the offer over the phone,do not negotiate. Ask to come in to discussit face to face. You want to be able to readthe potential employer’s reactions, and youcan’t measure his or her reactions to whatyou’re saying over the phone.

Deflect criticism. Sometimes a potentialemployer will comment on how tough anegotiator you are or how interested youseem to be in the financial aspect of the job.Be prepared to turn this into a positive bysaying something like, “Well, negotiating isan important skill in business, and I intendto negotiate just as hard when I start work-ing for you.”

Negotiate future increases. Look for waysto work in discussing when the next salaryreview is. Maybe once you’ve agreed to asalary, you can ask what their policy is interms of salary increases. Ask about bothcost-of-living increases and discretionaryincreases. Try to make this period as shortas possible. Most experts seem to think thatsix months is a good time frame to strive forin terms of meeting about salary increases.Chapman suggests the following approach:“You could say, ‘I want to hit the groundrunning here. In the first few weeks I’d liketo set some challenging but achievable goals… and in six months, when we take a goodlook at my performance, I wonder if wecould also look at salary at that time.’” Headvises to use your best judgment withregard to trying this: “I wouldn’t do it allthe time. The circumstances will allow youto tell if it’s appropriate or not.” This strate-gy can be particularly useful if you’rechanging specialties and your employer maywant to give you a salary at the low end ofthe range because of lack of experience. Youcan accept the offer but negotiate for setgoals and a review within six months inwhich your performance can be discussed,getting the employer to agree that if you’vemet specified goals like an experienced pro-fessional, then you will be considered for araise to the middle or top of the range.

Of course, these are only the basics.Further research, especially in terms of nego-tiating tactics, will help you develop thestrategy that works best for you—and thatleads to the salary (and benefits) that youdeserve.

(continued from p. 6)

FEELINGEXPRESSIVE?The key to the content in ACAMSToday is the expertise of ourmembers. Is there a topic youwant to cover? Can you tell usabout a tough problem yourecently ran into—and solved? Isthere a new laundering schemeyou’ve discovered that you cantell us about? All of these—andmore—are great topics for arti-cles. If you’d like to contribute toACAMS Today, please contactAbel Delgado, the editor, atadelgado@acams.org.

STAY ON TOP OF YOUR AML GAME

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THE NEXT STEP?

AML Training: Is Yours Up to Par?June 23, 2005, 1:00 PM-3:00 PM EST

Internal AML InvestigationsAugust 4, 2005, 1:00 PM-3:00 PM EST

What Went Wrong: How to Keep Your Institution from Becoming Another AmSouth or RiggsOctober 20, 2005, 1:00 PM-3:00 PM EST

Tracking Wire Transfersto Stop LaunderersDecember 8, 2005, 1:00 PM-3:00 PM EST

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