Wednesday, July 5, 2023


We note that a large number of AML compliance officers are reaching their retirement age; many were hired after 9/11, when the USA PATRIOT Act caused banks around the world to expand their compliance staff. Now, new people are being actively solicited. Here are my thoughts on the subject:

(1) MAKE SURE THAT YOUR NEW HIRES HAVE A WELL-ROUNDED EDUCATION. A good liberal arts degree generally insures both Cultural Literacy*, as well as Geographic Literacy*, qualities which go a long way to helping one to recognize financial crime, and specifically money laundering, while in progress.

(2) TEACH THEM TRADECRAFT BEFORE THEY GO ON DUTY. I cannot stress enough the importance of having a knowledge of both advanced as well as esoteric money laundering methods and techniques. Since I have covered this subject extensively in prior articles in this space, I will assume that my message has gotten through to compliance directors, and that training budgets are being adjusted accordingly. There's nothing worse than a deficiency in Tradecraft knowledge.

(3) GIVE THEM READY ACCESS TO LEGAL COUNSEL AND SUPERVISORS. Questions will always come up in real time, and they must have someone to consult with on time-sensitive matters, and especially at the end of the business day, when they spot something that they do not understand.

(4) DON'T BE CHEAP WITH CONFERENCE AND EVENT ATTENDANCE REQUESTS. Send them to those relevant AML/CFT conferences, so that they not only learn, but network with regulators, law enforcement, and yes their brother and sister compliance officers at other banks. One day, that casual friendship acquired at a conference could pay off in a big way.

(5) PROMOTE FROM WITHIN. Do not be afraid to give your younger hires more responsibility in critical areas, especially when they already excel at every routine task you have given them.

(6) GIVE THEM SOFTWARE PLATFORMS THAT WORK. Don't scrimp on systems that are effective. Your budget should be expanded to accommodate their needs, and make them successful. 

Above all, mentor these new compliance officers, because you yourself will not be around forever, and someone will need to step into your shoes one day. Make sure that person is qualified, please.


* I have explained the importance of these qualities in prior articles; if you still have questions, email me at   .

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