Money Laundering, Terrorist Financing and Financial Crime
Sunday, January 28, 2024
WHAT IS THE IDEAL PREPARATION TO BE A COMPLIANCE OFFICER THAT CONDUCTS TRANSACTION MONITORING FOR TRADE-BASED MONEY LAUNDERING AT A BANK WITH INTERNATIONAL CLIENTS?
While we have previously detailed how the knowledge of advanced TBML techniques is mandatory for any compliance officer who is responsible for Transaction Monitoring at their place of employment, who is involved in Trade-Based Money Laundering detection and interdiction, perhaps we should start at the beginning. What is the best training and experience for anyone who contemplates a career in AML/CFT, focusing on TBML? If I was giving advice to someone headed off to his or her first year at university, and who wants to ultimately be in banking, but in the compliance sphere, here is what I would tell them: 1. You need a good general education on how the business world operates; this means not a Liberal Arts degree, but a B.B.A. If for some reason, a Business degree does not excite you, then the other way you can achieve that level of necessary business literacy is law school after college. If your level of ambition includes a desire to one day be a Director of Compliance at a major bank, look at how many of those positions are held by lawyers, and govern yourself accordingly. Also, regular readers of my articles over the last three decades know that I am a firm believer in the training in Issue Perception, which is a learned skill at law school, which uses the case method to teach black-letter law, and demands that you extract the relevant issues to learn legal principles. 2. If you are dead-set on a TBML-focused career, some practical experience, hopefully during summers out of school, or part-time, at freight forwarders, shipping lines, air cargo companies, and any commercial transportation position which will make you intimately familiar with the mass of documents that are employed in international transport of goods. if you are on a first-name basis with the manner in which maritima and aviation cargo transportation is conducted, you will be light-years away from your fellow compliance officers who are trying to puzzle their way through the paper trail of international commerce. 3. Optional, but invaluable, is previous actual field duty in the shipping industry, which will not only broaden your horizons, but give you a window into how such transport happens. No, I don't mean shipping out on a tramp steamer, but there are openings available that might open your eyes. We call that Getting your Hands Dirty. Don't rule out a post-college short hitch in the Navy or Air Force before law school. It has worked for a lot of us, so do not dismiss it out of hand. Armed with this unique background, you are going to get hired before others with more pedestrian qualifications; good luck in the tough and unforgiving world of TBML AML/CFT.