Lately, this seemingly basic question seems to occupy the minds of AML Compliance Officers and operational types alike.
As it turns out, the answer is simple: You need to develop your AML department like a professional sports team – gather a healthy balance of veterans, free agent acquisitions, and a strong core of promising rookies developed by your farm system.
On its face, this might appear as an oversimplified metaphor to a pressing issue, but my work with financial institutions around the country suggests otherwise.
The Classic Hiring Mishap
The classic hiring mishap occurs when AML compliance and operations folk limit their hiring pool to persons with “industry designations” and “multiple years of experience” at the Analyst level. Of course, those are well-established qualifications, but the fact of the matter is those people are in high demand, short supply, and oftentimes come with bad habits learned from previous employers.
You will miss a significant number of slam dunk Analyst hires if you focus on industry designations and experience alone.
The Five Qualities of a Good Analyst
So what should you focus on in the hiring process? Look for smart people. Focus on individuals – irrespective of background – who possess the five unassailable qualities of a good Analyst: (1) reading ability; (2) curiosity; (3) writing ability; (4) research skills; and (5) attitude (“the Five Qualities”).
Stop and think about it – what are we asking our Analysts to do on a day-to-day basis:
- Gather, read, and analyze Customer Due Diligence / Know Your Customer information
- Perform research on customer, owners, signors, and counterparties
- Analyze transactions for out-of-pattern activity and known money laundering typologies
- Synthesize and conceptualize the information mentioned above
- Summarize findings in a crisp, well-written paragraph
- Complete all of these tasks within a 15 – 45 minute timeframe; and
- Work within a team environment
Some or all of the Five Qualities are omnipresent in virtually every aspect of the Analyst’s role. If you cannot find Analysts with designations or experience, then you need to identify and recruit people with the Five Qualities and make them into good Analysts yourself.
In other words, you will rarely be disappointed when you hire smart people.
Frank Ewing is the partner in charge of operations and subject matter expertise in the firm’s risk and compliance practice. He is a licensed attorney in the state of New York and an anti-money laundering expert with over 13 years of combined professional experience in global consulting, banking, and law. Mr. Ewing has extensive hands-on experience in the areas of anti-money laundering compliance, regulatory enforcement actions, regulatory affairs, internal audit, commercial litigation, corporate investigations, fraud, and risk management.