Finding Work in Anti-Money Laundering
Christian FocacciFounder, AML Source
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals2
Intro to Anti-Money Laundering (“AML”)
Anti-money laundering ("AML") is the term used in the financial industry to describe the controls that financial institutions and other regulated entities undertake to prevent, detect, and report money laundering activities.
Money laundering is the process of making illegally-gained proceeds appear legal, and typically involves three steps: placement, layering and integration.
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals3
Three Stages of Money Laundering
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Timeline of AML Regulations
1970 1986 1988 1992 1994 1998 2001
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Established requirements for recordkeeping and reporting by private individuals, banks and other financial institutions.
Designed to help identify the source, volume, and movement of currency and other monetary instruments transported or transmitted into or out of the United States or deposited in financial institutions
Required banks to (1) report cash transactions over $10,000 using the Currency Transaction Report; (2) properly identify persons conducting transactions; and (3) maintain a paper trail by keeping appropriate records of financial transactions
Bank Secrecy Act (1970)
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Criminalized the financing of terrorism and augmented the existing BSA framework by strengthening customer identification procedures
Prohibited financial institutions from engaging in business with foreign shell banks
Required financial institutions to have due diligence procedures (and enhanced due diligence procedures for foreign correspondent and private banking accounts)
Improved information sharing between financial institutions and the U.S. government by requiring government-institution information sharing and voluntary information sharing among financial institutions
Expanded the anti-money laundering program requirements to all financial institutions
Increased civil and criminal penalties for money laundering
USA PATRIOT Act (2001)
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AML Department Structure
Prevention Detection Reporting
KYC, CDD, and EDD (On-boarding)
Oversight, Policy, and Compliance Officers
AML Technology
AML Alert and Sanction Monitoring
AML Investigation and SAR Filing
While banks operating in the same country generally have to follow the same AML laws and regulations, financial institutions all structure their AML efforts differently
Financial institutions must employ large numbers of employees with varied skill-sets in order to comply with these laws
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AML Job Descriptions
KYC, CDD, and EDD (On-boarding)Professionals conducting Know Your Customer (KYC) and Customer Due Diligence (CDD) are the first lines of defense against money laundering. Their jobs involve collecting the required identifying information on new clients and risk rating the clients based on geography, industry/occupation, product, political status, and reputational risk.
AML Alert and Sanction MonitoringOnce clients make it though the on-boarding stage, the financial institution will usually employ an automated transaction monitoring system to detect any transactions indicative of money laundering or terrorist financing. The alerts generated by these systems are reviewed by teams of analysts to determine the nature of the transactions.
AML Investigation and SAR Filing Depending on the size of the institution, alerts deemed unusual may be further escalated to investigative teams to review the activity and determine if a suspicious activity report (SAR) needs to be filed. Larger financial institutions utilize several investigative AML groups, usually specializing in a specific product or line of business.
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AML Job Descriptions (cont’d)
Oversight, Policy, and Compliance OfficersProfessionals in the above categories focus on making policies for various AML groups and dealing with situations that are new or don’t fit inside the box. They must also be forward thinking and aware of upcoming trends in the industry to ensure that their bank is not exposed to unwanted risk. Whereas on-boarding and investigative positions are considered more production driven, many of the duties of the individuals in the above roles are more theoretical in nature.
AML TechnologyAML Technology is the behind the scenes group that makes many AML jobs possible. They can implement, maintain, and fine-tune the databases that store client information, and the monitoring systems that detect money laundering or block sanctioned transactions. Due to the advances in technology and the very specific skill sets needed, this is probably one of the most in demand positions in AML.
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Whether it is the long hours or high stress, more and more attorneys are making the transition to the AML field. There are many factors to consider before making this transition.
Attorneys in AML
Rapidly growing industry
Stable work/life balance
Interesting subject matter with a global nature
PROS You won’t be
practicing law
Potentially lower compensation
Some roles are very production driven
CONS
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Focus Your ResumeWhile you may have achieved many note-worthy accomplishments in your law career, many of those are most likely not applicable to your new AML position. Trim the fat on your resume. If your area of practice involved criminal law or white-collar crime, focus on your expertise there. If you don’t have experience in these areas, highlight your analytical, investigative, and writing skills. It can also help to have a short, specific, and clear objective section for why you want your new position.
NetworkTry to connect with as many people as you can who are currently working in the AML field. It usually happens that you get opportunities from some of the most unlikely people, so never pass up a networking opportunity. LinkedIn is a great avenue to find AML professionals and networking groups. These groups are free and many have in-person meetings and seminars periodically. While not free, it may also be a viable option to join a professional association, such as ACAMS or ACFCS.
Consider ConsultingApplying for consultant or temporary positions is an excellent way to gain exposure and experience in the AML field. Based on many factors, there can be a lower barrier for entry into the field if you come in as a consultant. In addition to gaining relevant experience, you will also gain numerous of networking opportunities.
Tips for Transitioning into AML
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Average AML Salaries
Years of Experience Salary Range
Less than 3 years Up to$75,000
3 - 5 years $75,000 - $100,000
5 - 10 years $100,000 - $125,000
Greater than 10 years $125,000+
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AML Job Hubs
City #
New York, NY 126
Newark, NJ 14
Chicago, IL 12
Englewood, CO 9
Buffalo, NY 8
Charlotte, NC 8
Columbus, OH 8
Los Angeles, CA 8
San Antonio, TX 8
Tampa, FL 8
Pittsburgh, PA 7
Jersey City 7
Statistics from the AML Source Job Report for August 2013
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Top Hiring Companies
Company #
JPMorgan Chase 79
Citi 46
BNY Mellon 15
Standard Chartered Bank 11
WesternUnion 11
CIT Group 11
HSBC 10
PwC 7
Sovereign Bank 7
Morgan Stanley 6
PNC Bank 6
Bank of America 5
Statistics from the AML Source Job Report for August 2013
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals15
Emerging Areas of AML
Global & high risk investigation groups
FATCA compliance
Regional and community banks
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Contact Information
Christian FocacciFounder
AML Source, LLCwww.amlsource.com
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