Finding Work in AML for Attorneys

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.


Three Stages of Money Laundering


Timeline of AML Regulations

1970 1986 1988 1992 1994 1998 2001


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)


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)


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


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.


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.


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


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


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+


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

http://blog.amlsource.com/2013/09/07/first-monthly-aml-job-report/


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

http://blog.amlsource.com/2013/09/07/first-monthly-aml-job-report/


Emerging Areas of AML

Global & high risk investigation groups

FATCA compliance

Regional and community banks


Contact Information

Christian FocacciFounder

AML Source, LLCwww.amlsource.com

[email protected]

http://www.amlsource.com/

Finding Work in AML for Attorneys

Career

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