2021 has been quite the ride in respect of the AML regime and it will continue to shift and move into 2022. From regulatory changes to technology advancements, it is exciting to see the continuous change when it comes to this growing space.
My observation has been the high turnover and shortage of good quality AML Compliance Officers. Yet, any forecaster would have guessed this. When you open a regime to 6,000+ companies, you WILL get a shortage in the market, and then following the initial period, there is the continuous inflow that is required to keep the market going. Type “Compliance Officer” into the Seek platform in Australia and it returns 1,329 hits. I only received 134 hits on the New Zealand platform. I have noticed smaller companies combining the role with existing staff members’ tasks and duties, so the amount of companies seeking persons with AML experience could grow over time.
So what should employers be looking for when hiring an AML Compliance Officer? I spend most of my days answering this question for clients and each organisation is different, however, I have three trending qualities that tend to work across the market.
1. Eager to learn [about AML] and apply in practice
You are in trouble if your AML Compliance Officer is in the land of “we have arrived” because of the following:
- It is a legal obligation to have adequate and effective policies, procedures and controls on training for your AML Compliance Officer. You aren’t meeting your obligations if you have an AML Compliance Officer that is unwilling to learn.
- The media is always giving us insight into the effectiveness of the regime based on other captured companies’ failings or live money laundering or terrorism cases.
- There are the changing regulations, the supervisor guidance, the information available by the NZ Police (FIU), other sector specific guidance. The AML Compliance Officer role involves continuous education where you always have something to learn and getting someone on board that is eager to get into this stuff and apply it to practice is GOLD!
2. Influential and great with relationships
This is where a cultural fit works really well. It is easy to hide in the back room of policy and forget about pragmatism. A good AML Compliance Officer understands all areas of the business and very closely understands your business culture. And how do you do this? By building relationships with those that understand the business and its customers.
I have heard jokes about receptionists being appointed to the role of AML Compliance Officer, but this is a viable option for a low risk business with limited resourcing. The reception area is typically the central point to an organisation, especially for customers and the distribution of products and services. The receptionist typically has a lot of knowledge about the organisation and can be hugely influential. Don’t overlook options due to industry snobbery.
I am not saying that every organisation should appoint their receptionist as the AML Compliance Officer, and a capabilities assessment should always be made when appointing a person to this role. My point is that it is the qualities of a person that we should look at rather than job titles. It is also about being creative in your search for the best solution for your business.
3. Asks a lot of the right questions
How can we improve this process? Why are we doing it this or that way? Are we managing our risk effectively or do we need to look at it from another angle? Natural problem solvers typically ask a lot of questions and these are the people that are improving our industry through the rise in technological advancements. Having a person on the team that asks a lot of the right questions is how you can create efficiencies, ease the process for customers and reduce errors in mitigating and managing your AML risks.
Data to help in the hiring process
We use strengths based assessing to gain insights into candidates applying for AML Compliance Officer positions. Ensuring you have the right person in the right seat is vital for ensuring money laundering and terrorism financing risks are managed in the organisation, and it can be helpful.
Other helpful experience
Experience in risk management, customer due diligence experience, assurance testing, account monitoring, policy drafting and training can also be helpful. Just note that there are plenty of providers where you can either outsource or organise training if you can’t find your unicorn.
To summarise
Ultimately, you need the right fit for your organisation, and that might look quite different when considering culture, risk ratings, and the budget. A candidate that has no risk management experience yet is eager to learn, can connect with your people with ease, and has a natural ability to problem solve is a great canvas for applying those AML learnings.
Getting compliance right is the first and most important step, and once you have that, you have the capacity to build efficiencies and effective processes that work for you and your customers. This is where I feel we are headed in 2022, and it will take great people to get us there.
Read more from Cleo Shortland as she discusses change management in ‘Driving successful AML change‘
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Vincent McCartney 
