Finding Work in AML for Attorneys
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Finding Work in AML for Attorneys

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Presentation to the New York Law School Compliance Working Group on the anti-money laundering (AML) industry.

Presentation to the New York Law School Compliance Working Group on the anti-money laundering (AML) industry.

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Finding Work in AML for Attorneys Finding Work in AML for Attorneys Presentation Transcript

  • 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