Thursday, July 13, 2023

ARE YOU RUNNING AN EFFECTIVE AML/CFT TRAINING PROGRAM, OR RELYING UPON INADEQUATE CERTIFICATE ACQUISITION?

 

For those compliance officers who live and die, based upon how many initials their staff can append after their name, indicating how many AML certificate programs they have completed, think again. Those programs, most of which area not academic degrees, but based upon passing exams, or attending seminars, are not resulting in a significant reduction of successful money laundering operations in the world's banks. If anything, money laundering has expanded exponentially, notwithstanding the plethora of AML/CFT alphabet-conferring programs that are offering what they claim are credentials in the field.

In the thirty years since the certificate programs became the rule, rather than the exception among compliance officers, the trillion dollars of successful money laundering operations has grown, even if we take conservative estimates. Laundrymen are taking full advantage of the options that the growth of technology has given them, and moved into new industries and fields that they previously ignored. The programs, which teach regulatory requirements, and rules-based procedures, are not getting the job done.

This means that the minimum required knowledge base of compliance officers has grown, while the certificate programs are studiously ignoring the problem. There are two issues that directors of compliance must now address regarding the training of their staff:

(1) Are they operating an in-house ongoing program that educates their staff in money laundering tradecraft, the actual methods and techniques employed by money launderers?

(2) Are they teaching the efficient use of AI-powered AML/CFT platforms, so that their staff, once savvy about recognizing and understanding money laundering techniques, can pick them out of all this new information now available to them?

The combination of tradecraft education and proper use of Artificial Intelligence-equipped systems will afford your staff the ability to find the laundrymen through the identification of their techniques. Pairing advanced knowledge with newly-available information is the trick to uncovering ongoing money laundering in your bank. Go find those laundrymen, and put those certificates in the drawer; they are not helping you.

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