1. MAY/JUNE 2005
VOL. 4 NO. 3
Official newsletter
of the Association
of Certified Anti-
Money Laundering
Specialists
www.acams.org
ACAMSTODAY
Advancing the professional knowledge of
those dedicated to the detection and
prevention of international money laundering
A Look at the
Job Outlook for
AMLFrank Hannah wasn’t even looking for a job
when he found one. His bank was acquired by
a larger one, with lots of opportunities for
mobility. “I was contacted by a colleague who
said, ‘We really need to get our anti-money
laundering (AML) processes beefed up. Are
you interested?’”
It was that simple. While this definitely
speaks to the value of networking, there’s anoth-
er factor of Frank’s story to consider: “Prior to
getting this call I would get three calls a month
from headhunters looking for AML officers,” he
says. So how typical is Frank’s story? And just
how hot is the AML job market right now?
So what is the current state of AML hiring?
Well, while hard numbers aren’t available to
provide a clear-cut outlook, it is possible to
get a sense of what it’s like out there.
Recruiters specializing in the financial servi-
ces industry talk to employers every day and
find out firsthand what their AML needs are.
In addition, we were also able to speak to
Betty Jo Zbrzeznj, director of the AML office
for Wachovia, who discussed with us the
bank’s efforts to expand this department over
the past few years.
Through this, we were able to shed at least
some light on certain key aspects of the hiring
outlook 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 of
sales for jobsinthemoney.com, an employment
website for financial professionals. Len
Adams, CPC, the CEO of Adams Consulting
Group, a recruiting firm based in New York,
agrees, describing the market as “very
strong.” In 2001, Adams rarely received calls
from employers looking for AML profession-
als, perhaps one every few months. He now
averages two to three calls per week.
For its part, Wachovia has doubled its AML
staff compared to three years ago. Zbrzeznj
cites 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 young
field. The fact is, up to this point, no one has
conducted an industrywide study focused on
hiring trends in the field. The U.S. Bureau of
Labor Statistics offers no employment projec-
tion for AML specialists, and internationally
no studies of the profession’s hiring outlook
are available.
Employers could offer some answers, but
it’s not easy to obtain them. Staffing informa-
tion is not something that is readily dis-
closed. With banks, obviously the biggest
employer in AML, this could be because AML
compliance staff numbers are embedded in
overall compliance numbers and, therefore,
are not easy to ascertain. Also, there is specu-
lation by some that banks are concerned
about being second-guessed as to whether
adequate resources are being deployed and
are therefore reluctant to discuss specific
numbers. And with government agencies,
internal policies generally prohibit them from
offering specifics on the topic of hiring trends
in certain areas. (continued on p. 8)
INSIDE
2 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 News
Tips for Training
Financial Investigators
www.acams.org/espanol

2. ACAMSTODAY
2 | ACAMS TODAY MAY/JUNE 2005
A WORD FROM
AN ADVISORY
BOARD
MEMBER
As we enter late spring and
early summer, the insurance indus-
try is anticipating the U.S. Treasury
Department’s release of the USA
Patriot Act regulations for product
providers: the basic Anti-Money
Laundering Program and Suspicious
Activity Reporting guidelines will
possibly bloom this May.
Once the final regulations are
published, the insurance industry
will have anywhere from 90 days to
6 months to establish proper com-
pliance programs, as well as poli-
cies, procedures and controls for
reporting suspicious activity.
Although the Treasury
Department has stated that out-
reach and education will be provid-
ed to the industry, many ACAMS
members are already on their way
to implementing the necessary pro-
cedures for their company’s pro-
grams. Many of these are based on
the extensive information, guidance
and training that ACAMS offers to
assist anti-money laundering spe-
cialists with the detection and pre-
vention of money laundering.
I encourage you as an ACAMS
member to utilize the tools it pro-
vides, and as you continue to for-
mulate your programs, look for
opportunities to participate in web
seminars or share your ideas and
inquiries on the ACAMS Listserv.
Remember that your fellow ACAMS
members in the financial industry
have already been through the ini-
tial process and can assist you in
making your program flower.
Regards,
L. Kim Estrada
AVP-Compliance Officer
Western Reserve Life Assurance
Co. 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 serve
three years in prison for money laundering.
Toronto attorney Simon Rosenfeld was arrested
in 2002 as part of a joint sting operation conduct-
ed by the Royal Canadian Mounted Police
(RCMP) and the United States’ Federal Bureau of
Investigation. The sting, called Bermuda Short
and focused on stock price manipulation and
money laundering schemes, netted 50 other peo-
ple besides Rosenfeld.
RCMP undercover operative Bill Majcher
posed as member of a Colombian drug cartel that
supposedly was looking to launder millions of
dollars. Majcher met several times with
Rosenfeld, secretly recording conversations in
which the attorney boasted about his money
laundering experience and the offshore accounts
he had been operating for over 20 years. He also
mentioned his organized crime contacts and said
he had previously lied under oath.
According to the Toronto Globe and Mail,
Rosenfeld claimed to earn $3 million Canadian
dollars per year but reported only $25,000 per
year for taxes. The newspaper further reported
that prosecuting attorney Rosemary Warren asked
for a seven-year sentence, arguing that lawyers
are key in money laundering and a stiff sentence
would serve as a deterrent. But Madam Justice
Tamarin Dunnet stated that due to sentencing
guidelines established in other money laundering
cases, three years was appropriate.
Myanmar Closes Two Banks
for Breaking Laws
Myanmar, one of the three countries left on
the Financial Action Task Force’s list of non-
cooperative countries, has shut down two private
banks for violating the country’s banking laws.
The Associated Press reported that Myanmar’s
Ministry of Finance and Revenue revoked the
licenses of Asia Wealth Bank and Myanmar
Mayflower bank on March 31. A representative
from the Ministry made the announcement on
state television, saying, “It was found that these
two banks have not strictly followed the banking
regulations.” However, the Ministry did not spec-
ify exactly what the banks did—or did not do—
with regard to banking regulations, nor which
regulations were not followed.
The United States State Department has
accused both of these particular banks of laun-
dering money and of having ties with Southeast
Asian drug traffickers.
In addition, in December 2003 the Myanmar
government announced that it had been investi-
gating these two banks with regard to the coun-
try’s anti-money laundering laws, which at that
point had only just come into effect. The investi-
gation was to have lasted three months, and the
banks could have had their assets frozen if found
guilty of laundering. But no results of that inves-
tigation were ever made public. The Ministry of
Finance and Revenue’s announcement did not
address whether the closures were related to this
previous investigation. Central bank administra-
tors will take over operations at both banks.
ACAMS
Chairman: Daniel Soto, CAMS
Executive Director:
Saskia Rietbroek-Garces, CAMS, MBA
Program & Training Manager:
Efraín Venezuela, MS, Ed.D.
Member Services: Patricia Paiz
Web Development: Diego Sanz
Membership Coordinator: Perla Ortiz
Editorial and Communications Manager: Abel Delgado
ACAMS ADVISORY BOARD
Chair: Daniel Soto, CAMS, Anti-Money Laundering Compliance
Executive, Bank of America, United States
Hussam A. Al-Abed, AML Consultant, Jordan
Mary Bhawnani, Senior Vice President-AML Relationship Manager,
ABN AMRO Bank, United Kingdom
Nina Boteva, CAMS, Partner, Boteva & Kantutis, Bulgaria
John J. Byrne, Director of the Center for Regulatory Compliance,
American Bankers Association, United States
Garry Clement, CAMS, Chief of Police, Cobourg, Canada
L. Kim Estrada, CAMS, AVP-Compliance Officer, Western Reserve
Life Assurance Co. of Ohio, United States
Al Gillum, CAMS, Postal Inspector (Ret.), United States
Jorge Guerrero, CAMS, President, Optima Compliance and
Consulting, United States
Charles A. Intriago, President, Alert Global Media, Inc., United States
Michael R. McDonald, CAMS, AML Consultant, McDonald &
Associates, Inc., United States
James Richards, Global AML Operations Executive, Compliance
Risk Management, Bank of America, United States
Nancy Saur, CAMS, MICA, Compliance Officer, Bodden Corporate
Services Ltd., Cayman Islands
Richard Small, Director of Global Anti-Money Laundering,
Citigroup, Inc., United States
Patricia Torres, CAMS, Senior Manager of Financial
Intelligence, Mancera, Ernst & Young, Mexico
Jos de Wit, CAMS, AML Consultant, The Netherlands
ACAMS Today is designed to provide accurate and authoritative
information concerning international money laundering controls
and related subjects. In publishing this work, neither the authors
nor the association are engaged in rendering legal or other pro-
fessional service. The services of a competent professional should
be 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-S
Miami, FL 33131, USA
Tel. 1-305-373-0020; Fax 1-305-373-7788;
E-mail: info@acams.org
Website: www.acams.org • www.acams.org/espanol

3. 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—then
came the offer. You accepted. A happy end-
ing, right? Not necessarily.
You may well have sold yourself short in
a big way, missing out on thousands of dol-
lars because you didn’t negotiate. According
to salary negotiations coach Jack Chapman,
author of Negotiating Your Salary: How to
Make $1,000 a Minute, this is a common
mistake that candidates make. He says that
two other critical mistakes that candidates
make are “talking about salary first” and
“thinking that the job is what it is and it
can’t be any bigger.” So how to avoid these
mistakes? Here’s a look at some basic strate-
gies to employ to get the best price for your
services—and maybe even a big raise before
you start your new job.
Doing Your Homework
You need a starting point for negotiations,
hard data you can back up if an employer
challenges you. So you need to research
what your desired position pays, factoring in
experience level and where you live. There
are a variety of places to get this informa-
tion. Chapman recommends several web-
sites, including salary.com,
careerjournal.com and payscale.com, where
you can research salaries for your desired
position. Some websites will even prepare
an individualized report for an extra fee.
Now, anti-money laundering may not
appear on these sites because it’s so new. Try
to see if you can obtain an individualized
report and if you can’t, try other sources:
scan the job openings posted on the ACAMS
job bank and talk to financial services
recruiters, who also may put you on to new
jobs opening up.
Also, canvass your contacts: peers with
whom you have a good relationship can give
you a ballpark salary to work with. In addi-
tion, ACAMS will soon launch the first-ever
worldwide AML salary survey, an additional
resource that you’ll soon be able to use.
Besides salary, factor in all the benefits
you want—and which ones you think can be
negotiated. Chapman suggests this strategy,
and you’ll see why when we get into tactics.
Ultimately, your goal is to establish a
salary range and median to give you more
flexibility for negotiation.
Show Me the Money
Once you have your range set with hard
data, then you get into the actual negotiation
process. Here are some tips to handle it from
the beginning.
Avoid the current salary trap. The experts
all agree that you should not reveal what
you make when a potential employer asks
you, because that will be the starting point
for negotiations, not the amount that you
researched. Interviewers ask this question to
weed you out in case your answer is too
high—and to gain a negotiating advantage.
So how do you answer this question?
Chapman offers several ideas: “Listen, I’d be
glad to talk about that, but is this the right
time? Are we in a place where you’re making
an offer?” The potential employer can only
say “yes” or “no.” You can further throw
them off this question, says Chapman, by
saying: “I’m sure we can get to a good salary.
I think we should focus on whether I’m the
right fit.” Or you could turn it around: “If
you’re asking, it could be because you’re
worried about your budget. What kind of
range did you have in mind?” At that point,
they respond and you get a sense of where
they are. However, do not agree with their
figure. The experts say that your response
should be more neutral, as in, “That figure
seems to fit within my range.” Then try to
steer the conversation
Getting
a Raise
Keys to Smart Salary Negotiation
(continued on p. 11)
Before You Even Start
ACAMS
FINGER ON
THE PULSE
How would describe the
AML job market these
days?
Exploding—more opportuni-
ties than ever (15) . . . . 44%
Stable—there are jobs out
there, but not an enormous
amount (15) . . . . . . . . 44%
Not good—it’s a tight mar-
ket and hard to find a good
job (4) . . . . . . . . . . . . 12%
Total votes: 34
Stay tuned to www.acams.org
for new polls so you can cast
your vote!

4. ACAMSTODAY
(continued from p. 1)
8 | ACAMS TODAY
MARK THESE DATES
MAY/JUNE 2005
growth during that same period, along with
the heightened regulatory focus on AML.”
But heightened regulations are not the only
demand driver. Both Zbrzeznj and recruiters say
it comes down to the simple principle of supply
and demand, with a relatively small pool of
experienced AML professionals out there.
According to Adams, “There has been a scarcity
of qualified people. This is due to the fact that
the function itself has really increased over the
past few years. Thus, there is not an abundance
of people that were performing the function as a
full-time responsibility.” Cruickshank agrees:
“Demand is driven by a lack of qualified candi-
dates with the right skills.”
Where the Jobs Are
Cruickshank says that he sees the most
demand from the banking and financial servi-
ces sectors. And while he observes that larger
banks seem to have a greater volume of overall
demand, he notes that “regional and communi-
ty banks are also looking for professionals with
relevant experience.” Connie Fenchel, founder
and executive recruiter for amlexperts.com, an
international search firm for AML and BSA
independent consultants that is based in
Washington, D.C., and Daytona Beach, Florida,
has a different perspective. “Actually, I believe
there is a greater demand in non-banking busi-
nesses, such as money services businesses
(MSBs),” she says. “Banks have been required
to 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 are
desperate for knowledgeable, qualified AML
experts,” says Fenchel.
What They’re Looking For
So what are the ingredients to an outstand-
ing AML resume? Adams simply states that he
sees employers looking for “3+ years of experi-
ence,” while Cruickshank has seen an interest
in “candidates with anti-money laundering
experience from all career levels.” For her part,
Fenchel has seen the experience required by
institutions to vary with the position, though
she says employers are focused not just on
general AML experience but rather on AML
experience within a particular industry, such
as MSBs or insurance. Zbrzeznj says that
Wachovia seeks a variety of experience types,
such as former law enforcement officers and
former regulators.
The Emerging Image
Without question, we don’t yet have a
nuanced portrait of the AML job market, full of
the exhaustive detail that empirical evidence
can supply. However, the perspectives from
sources involved in hiring do offer a rough
sketch, one that suggests clearly that AML is in
demand and that experienced professionals in
the field are poised to enjoy more opportunities
than ever before. The next step, of course, is a
study, preferably at the international level, that
will truly allow AML professionals to under-
stand their market value and career potential.
May 2
ACAMS
CAMS Examination Preparation Seminar (en español)
Cartagena, Colombia
http://www.acams.org/certification/certification_examprep.aspx
May 4-6
2005 West Coast Anti-Money Laundering Forum
San Francisco, United States
http://www.wcamlforum.org/
May 11
The Institute of Money Laundering Prevention Officers
Second Annual Conference
West Midlands, United Kingdom
http://www.imlpo.com/conference/home.shtml
May 18-19
Complinet
Complitech 2005
London, United Kingdom
www.complitech.co.uk
May 19-20
The 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 21
ACAMS
CAMS Examination
Amsterdam, Netherlands
http://www.acams.org/certification/certification_examdates.aspx
May 27
ACAMS
CAMS Examination Preparation Seminar (en español)
Mexico City, Mexico
http://www.acams.org/certification/certification_examprep.aspx
June 3
ACAMS
CAMS Examination Preparation Seminar
Los Angeles, United States
http://www.acams.org/certification/certification_examprep.aspx
June 12-15
American Banker’s Association
ABA Regulatory Compliance Conference
Baltimore, United States
http://www.aba.com/Conferences+and+Education/ce_regulatory_com-
pliance.htm
June 17
ACAMS
CAMS Examination
Cartagena, Colombia
http://www.acams.org/certification/certification_examprep.aspx
June 23
ACAMS
Web Seminar
AML Training: Is Your Training Up to Par?
http://www.acams.org/webcasts/series/Webcastseries.aspx#Second
June 25
ACAMS
CAMS Examination
Grand Cayman, Cayman Islands
http://www.acams.org/certification/certification_examdates.aspx

5. ACAMS TODAY | 11MAY/JUNE 2005
back to how you can help the company. The
goal is to make yourself a prime commodity
so that when the conversation turns back to
salary, they’ll want you—and be willing to
pay big for your services.
Just say “Hmmm.” When the offer does
come, advises Chapman, “use a four-letter
word without any vowels that’s not in the dic-
tionary but that everybody uses: ‘Hmmm.’ So
if they offer you 50,000, you go “50 thousand …
Hmmm … allow for some silence.” That’s
when they’ll ask you if that figure is okay or
not. But don’t answer it.
Or try the echo. Daniel Porot and Frances
Bolles Haynes recommend a similar tech-
nique in their book, 101 Salary Secrets: “the
echo.” It basically means repeating the offer
while 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: just
echo the highest figure of the range. Salary
consultants say that either approach could
make the potential employer think that this
first offer is way too low and thus offer an
increase right on the spot.
Table salary discussions once more. Once
the figure is out there and you’ve “hmmmed”
or echoed, Chapman suggests segueing to bene-
fits. For example, if a potential employer offers
you $50,000 per year, Chapman recommends
saying: “Before we dig in to that, there are a
couple of small things that we should clear out
of the way.” That’s when you go for the benefits
that you feel are most negotiable. For example:
“I presume that at this level, if I needed three
weeks vacation rather than two, we’d be all
right there, correct?” And you proceed from
there. “They’re eager at that point to get to the
base salary,” explains Chapman. “That’s your
best 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 you
get into salary discussions, you can politely
bring up the lack of benefits in your argument
for more money.
Get into range. Once you’re back at salary,
your next move depends on what their offer
is. It could be at the top of your range, below
the bottom or just right. Scenarios 1 and 3 are
generally unlikely, so let’s look at the low
offer. You counter with your researched range,
which you can bracket, suggests Chapman.
For instance, if the researched range is
US$45,000 to US$50,000, bracket the range by
telling the potential employer that your
researched range is US$47,000 to US$50,000.
William Cohen, Ph.D., author of Break the
Rules: The Secret Code for Finding a Great Job
Fast and professor of business at Touro
University International, offers another option.
He suggests telling the employer that the job is
at least worth $X, a figure 10 percent above the
employer’s offer. This is tricky, he explains,
and a call you need to make on the spot. He
feels that it’s unlikely that an employer will
eliminate you from contention just because
you 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 discuss
it face to face. You want to be able to read
the potential employer’s reactions, and you
can’t measure his or her reactions to what
you’re saying over the phone.
Deflect criticism. Sometimes a potential
employer will comment on how tough a
negotiator you are or how interested you
seem to be in the financial aspect of the job.
Be prepared to turn this into a positive by
saying something like, “Well, negotiating is
an important skill in business, and I intend
to negotiate just as hard when I start work-
ing for you.”
Negotiate future increases. Look for ways
to work in discussing when the next salary
review is. Maybe once you’ve agreed to a
salary, you can ask what their policy is in
terms of salary increases. Ask about both
cost-of-living increases and discretionary
increases. Try to make this period as short
as possible. Most experts seem to think that
six months is a good time frame to strive for
in terms of meeting about salary increases.
Chapman suggests the following approach:
“You could say, ‘I want to hit the ground
running here. In the first few weeks I’d like
to set some challenging but achievable goals
… and in six months, when we take a good
look at my performance, I wonder if we
could also look at salary at that time.’” He
advises to use your best judgment with
regard to trying this: “I wouldn’t do it all
the time. The circumstances will allow you
to tell if it’s appropriate or not.” This strate-
gy can be particularly useful if you’re
changing specialties and your employer may
want to give you a salary at the low end of
the range because of lack of experience. You
can accept the offer but negotiate for set
goals and a review within six months in
which your performance can be discussed,
getting the employer to agree that if you’ve
met specified goals like an experienced pro-
fessional, then you will be considered for a
raise 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 the
strategy that works best for you—and that
leads to the salary (and benefits) that you
deserve.
(continued from p. 6)
FEELING
EXPRESSIVE?
The key to the content in ACAMS
Today is the expertise of our
members. Is there a topic you
want to cover? Can you tell us
about a tough problem you
recently ran into—and solved? Is
there a new laundering scheme
you’ve discovered that you can
tell us about? All of these—and
more—are great topics for arti-
cles. If you’d like to contribute to
ACAMS Today, please contact
Abel Delgado, the editor, at
adelgado@acams.org.

6. STAY ON TOP OF YOUR AML GAME
Gaining new knowledge and sharpening
skills are key in any profession—but
even more so in the fast-changing world
of anti-money laundering. ACAMS’ Web
Seminars are the quick, easy and
effective way to do this, with all the
hottest topics so you stay current and
get even better.
Prices: US$225 for members, US$295 for nonmembers, with 20 percent discounts available if you sign up for multiple seminars.
Signing up. It’s that easy.
Just go to www.acams.org
or call 1-305-373-0020 and mention
code 5DA111 to ensure your registration.
During each 2-hour program, top experts give you
insider, real-world information you can apply right
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up your whole staff today at one office location at
no extra charge.
WHY WEB SEMINARS?
• Convenience—no need to travel
• Simplicity—no special software needed,
just hook up and follow the seminar with
your web browser
• Access to experts—you’ll hear from the top
specialists in every AML topic covered
• Interactive—you can ask live questions by
e-mail or phone
• Cost-effective—one fee can train an entire
group
THE NEXT STEP?
AML Training: Is Yours Up to Par?
June 23, 2005, 1:00 PM-3:00 PM EST
Internal AML Investigations
August 4, 2005, 1:00 PM-3:00 PM EST
What Went Wrong: How to Keep
Your Institution from Becoming
Another AmSouth or Riggs
October 20, 2005, 1:00 PM-3:00 PM EST
Tracking Wire Transfers
to Stop Launderers
December 8, 2005, 1:00 PM-3:00 PM EST
2005 SEMINARS