The Inside Track: To bolster fincrime compliance training, learn how to see big picture, explain small details and profit from understanding roles, revenue pressures

The ACFCS Inside Track Series Provides Insight, Guidance and Practical Takeaways from ACFCS Thought Leaders.

By Casey Nelson
Senior Director of Training Solutions, ACFCS
April 29, 2022

In recent years, the financial crime compliance sector has gone through historic changes – in terms of regulations, responses to a global plague and being in some cases the victim, other instances the beneficiary, of rapid technological advances.

At the forefront of transformation in the anti-money laundering (AML) space is the U.S. Anti-Money Laundering Act (AMLA) of 2020, a sweeping series of updates to expand public-private partnerships, crack open beneficial ownership blind spots and, most significantly of all, shift the industry from fearing regulators to championing the needs of law enforcement.

These changes have taken on even more importance in recent months with Russia’s invasion of Ukraine, a move that has caused worldwide scorn, acrimony and condemnation against the Iron Curtain – and a unified sanctions barrage from the United States, United Kingdom European Union and others.

By some industry estimates the sanctions against Russia – starting with its annexation of Crimea in 2014 – have soared from around 2,000 to nearly triple that in roughly two months, a breakneck pace that has challenged banks and their corporate brethren to keep up.

The sanctions have sprawled, sprung and spilled like a gushing spigot beyond just Russia itself and the military industry complex of the country, but branched to the oligarchs that have propped up Putin and grown fat with wealth after snapping up whole industries after the fall of the Soviet Union.

These are all challenges on the mind Himamauli “Him” Das, the Acting Director of the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN), in Congressional testimony last week – a charged and spirited hearing that also highlighted a future with a more focused lens on training, for bank AML teams and examiners.

The AML Act has helped put FinCEN in the “position to address today’s challenges, such as illicit use of digital assets, corruption, and kleptocrats hiding their ill-gotten gains in the U.S. financial system, including through American shell companies and real estate,” he said in prepared statements.

It also highlights FinCEN’s unique tools and expertise to combat both “longstanding threats, as well as new ones, such as ransomware and other cyber-enabled threats and the use of the dark web to engage in illicit activity, such as the online exploitation of children.”

The AML Act also provides tools to approach innovations in a way that recognizes not only the opportunities they present, but the risks that they pose, Das said, a nod to record ransomware attacks, a vexing threat vector targeting banks, corporates and governments around the globe under the rubric of cyber-enabled fraud.

One of the purposes of the AML Act is to foster technological innovation and the adoption of new technology by financial institutions to make the AML/CFT framework more effective – efforts that also must be paired with rich and relevant training.

Improving in all areas more broadly is also a key driver of the AMLA.

FinCEN, as part of the many rolling goals, must “streamline, modernize, and update the AML/CFT regime of the United States,” with a nuance that sho