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Christian Focacci
Founder, AML Source
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
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.
2
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals 3
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
Bank
Secrecy
Act
Money
Laundering
Control
Act
Anti-Drug
Abuse Act
of 1988
Annunzio-
Wylie Anti-
Money
Laundering
Act
Money
Laundering
Suppression
Act
Money
Laundering
and
Financial
Crimes
Strategy Act
USA
PATRIOT
Act
4
1970 1986 1988 1992 1994 1998 2001
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
 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
5
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
 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
6
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
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
7
 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 Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
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 information on new clients and risk rating the
clients based on geography, industry/occupation, product, political status, and
reputational risk.
AML Alert and Sanction Monitoring
Once 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.
8
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
Oversight, Policy, and Compliance Officers
Professionals 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 Technology
AML 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.
9
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
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.
 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
10
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
Focus Your Resume
While 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.
Network
Try 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 Consulting
Applying 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.
11
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
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+
12
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
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
13
Statistics from the AML Source Job Report for August 2013
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
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
14
Statistics from the AML Source Job Report for August 2013
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
 Global & high risk
investigation groups
 FATCA compliance
 Regional and
community banks
15
AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals
Christian Focacci
Founder
AML Source, LLC
www.amlsource.com
contact@amlsource.com
646-450-0236
16

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Finding Work in AML for Attorneys

  • 2. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals 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. 2
  • 3. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals 3
  • 4. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals Bank Secrecy Act Money Laundering Control Act Anti-Drug Abuse Act of 1988 Annunzio- Wylie Anti- Money Laundering Act Money Laundering Suppression Act Money Laundering and Financial Crimes Strategy Act USA PATRIOT Act 4 1970 1986 1988 1992 1994 1998 2001
  • 5. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals  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 5
  • 6. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals  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 6
  • 7. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals 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 7  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
  • 8. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals 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 information on new clients and risk rating the clients based on geography, industry/occupation, product, political status, and reputational risk. AML Alert and Sanction Monitoring Once 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. 8
  • 9. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals Oversight, Policy, and Compliance Officers Professionals 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 Technology AML 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. 9
  • 10. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals 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.  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 10
  • 11. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals Focus Your Resume While 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. Network Try 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 Consulting Applying 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. 11
  • 12. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals 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+ 12
  • 13. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals 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 13 Statistics from the AML Source Job Report for August 2013
  • 14. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals 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 14 Statistics from the AML Source Job Report for August 2013
  • 15. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals  Global & high risk investigation groups  FATCA compliance  Regional and community banks 15
  • 16. AML Source - A Career Hub for Anti-Money Laundering & Financial Crime Professionals Christian Focacci Founder AML Source, LLC www.amlsource.com contact@amlsource.com 646-450-0236 16