“Here’s the deal…”
“I’m all ears.”
“On any given day you are as likely to be working on a terrorism case as you are on a drug smuggling ring. Everything from chop shops in major cities to gangs that traffic prostitutes across the border are all going to come across your desk.”
“Really?”
“Really. The work is fast and furious, though, and the emphasis is on bottom line up front, clarity and concision.”
“All the things they taught us...’
“Exactly. That’s why we are so good at this job. The specialty stuff you need to know you can learn on the job – it’s the basic skill set that they need.”
“What about the pay?”
“Good to great. The lowest number I heard was in the 40’s and that doesn’t include health benefits and 401K stuff. The highest number I heard…well, let’s just say, it’s real good. I even heard from one guy who gets all Federal holidays and four weeks of paid vacay a year…”
“Holy…”
“Yeah. Best part is you can work in any major city. You don’t have to be stuck in DC.”
“You’re kidding!”
“Nope. One more thing…”
“What?”
“You don’t need a clearance.”
“Damn. What’s this job called again?”
“Well, every organization seems to have their own name for it but most places I have seen call it a ‘Compliance analyst’.”
*************
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| https://flic.kr/p/9VDebQ |
Banks have a responsibility under these laws to take a hard look at any transactions that are “suspicious” and all transactions over $10,000 or pay hefty fines. This means that every bank has to have at least some of these positions on its payroll and that these positions can be found wherever the banks are.
After the transaction is analyzed, if it appears to be illegal, it and all of the evidence supporting the assessment has to be reported to the appropriate local, state or federal agencies. Oftentimes these are law enforcement agencies but occasionally, as in the case of terrorist financing activities, intelligence agencies (US and international) get involved.
The job is, according to the working compliance analysts I spoke with to compile this post, less about the numbers and more about “whether applicants can think in an independent / logical / creative way” and about “pattern recognition skills, bottom-line-up-front writing, and the ability to gauge the reliability and value of various sources.” The estimates these analysts make on a day to day basis can help law enforcement, intelligence agencies and the military stop crime, break up gangs and counter terrorism.
A quick look on Glassdoor.com under "compliance analyst" and it becomes obvious that starting salaries are quite good with regional banks averaging in the 40’s and multinational banks averaging in the 60’s for qualified entry-level analysts.
To get a better handle on the job and what it entailed, I reached out to a number of Mercyhurst alums working in the compliance arena to get some answers to my questions. Here, in a lightly edited format is what they said:
Note: Mercyhurst’s applied focus on intelligence studies coupled with its emphasis on not only national security but also law enforcement intelligence and intelligence in business seems to create a near perfect candidate for these kinds of jobs. Certainly, many of our alumni have gravitated to these positions over the years and have typically done very well in them (I have heard from several “Vice-presidents for Anti-money Laundering” from various regional and multinational banks in the course of putting this post together…).
Readers coming from academic programs that focus only on national security or analysts transitioning from the government to the private sector will likely find the answers below to be relevant but you might also find that these answers highlight gaps you might need to fill in order to compete successfully for these jobs.Q: Why do Mercyhurst intel studies grads make such good AML analysts?
From a Vice President-AML Compliance at a large multinational bank: Good entry level AML Analysts need to have three skills: critical thinking, writing, and data analysis. The Mercyhurst grads we hire walk in the door with very well developed critical thinking and writing skills. Data crunching/analysis (at least how it relates to AML) is the easiest of those three skills to develop on the job.
The type of analytic product AML analysts usually produce is called a Suspicious Activity Report. It’s a short summary of suspicious transactional activity - usually 1 -2 pages in length. Being able to identify suspicious patterns and clearly write about them in concise manner is not easy. Mercyhurst grads are primed to produce that type of product and they do it extremely well.
From a KYC Analyst at a large multinational bank: In my position as a KYC Analyst, I'm constantly synthesizing information from a variety of sources (including our internal databases, transactional analysis done by another analyst, client responses from a questionnaire, previous reviews of the clients, and external research online). I think that Mercyhurst's program produces effective KYC/AML analysts because it arms its students with pattern recognition skills, bottom-line-up-front writing skills, and the ability to gauge the reliability and value of various sources. Instead of accepting everything we find at face value, we dig deeper to find the underlying trends in play. We've learned how to write without bells and whistles to distract from the topic at hand. While some folks might be content with a single source, we seek out corroborating information. The goal of my job is to perform due diligence in order to establish a money laundering risk level for the clients. This involves a risk-based approach that in my opinion plays well into Mercyhurst's emphasis on Words of Estimative Probability and confidence levels.
From a Senior Associate in AML/Due Diligence at a large commercial bank: From my experience, most AML jobs typically involve the core basic skills currently being taught at the Intelligence Studies program, research, analysis and dissemination…I have been working in customer due diligence/KYC for close to eight years. Resourcefulness is key for these types of jobs. Those that are successful know how to quickly obtain customer information via open-sources or subscription databases. I say "quickly" because the workload is typically fast-paced and high-volume.
From an AML Compliance Officer/Analyst with a large multinational bank: As I was told upon hiring, "We can always teach you the banking terms, procedures, typologies, and show you the programs, but we can't teach you to think, understand, and analyze the data you see." …Being able to "see" trends and patterns through analysis is crucial for my role.
To expand upon that, our operational knowledge of Microsoft Excel (and mine with Access and other database design programs) was an extreme advantage. Open source analysis is also fundamental. Optimizing Google searches to identify entities or using Lexis Nexis is crucial for transactional understanding. Furthermore, we are able to evaluate reputable sites from those that are not. Our teachings in understanding risks around the globe and generally keeping up with the news and events of today are useful… (as is being able to) follow the money or the "story" and verifying it makes business sense…A notable advantage is I2 Analyst’s Notebook, which helps to portray the relationships of entities. In a way, when I investigate transactions, I too am looking for the linkage between the parties. Lastly, being able to see (and understand) suspicious or unusual patterns.
From an AML investigator with a large multinational bank: It is my feeling that Mercyhurst intel grads make good AML analysts because we have been taught to identify the gaps during an investigation… In addition to being able to successfully identify the blind spots in an investigation, I feel that a strong organizational background and concision helps Intel grads be so successful.
From a Compliance Analyst at a regional bank: In a nutshell, Mercyhurst students make excellent AML analysts because we have been taught how to conduct our investigations in an orderly manner. We have been taught how to properly and thoroughly collect information, what information matters, and how to put the puzzle together. We have been taught how to prioritize items. We have been taught how to work under intense pressure and get the mission done. But most importantly, we have been taught how to work as a team…
Q: What advice would you give a student interested in a career in AML?
From a KYC Analyst at a large multinational bank: This will probably sound obvious, but it will behoove you to learn about how financial institutions operate and, if you go into business banking like I did, to learn about various business models. This knowledge isn't necessary right off the bat, but having background knowledge in the nuts and bolts of it all can only be a boon…At an interview, a Mercyhurst student might consider speaking highly of the program's ability to turn out strong analytic writers with solid research skills.
From a Compliance Analyst at a regional bank: I would say to pay attention in the writing class and strategic, because of all the classes those two have helped me deal with the pressure and prioritizing of items. In terms of looking for jobs, AML is a growing field, and all our students will have to do is go into an interview knowing a little bit about AML and the BSA. Our program will speak for itself during the interview process.
From an AML Compliance officer/Analyst with a large multinational bank: For recent grads, if they are interested in this field, my best advice is to send as many resumes to as many different banks as possible…A lot of times, if you apply to a position and the person reviewing doesn't think you will fit there, they can refer you to a more appropriate job vacancy. So apply to everything! It is unlikely a hiring manager that knows what they are doing will dismiss your education. Focus on the worldly projects and internships analyzing large data-sets.
Also, use your social networking to reach out to established grads. I had a couple different people reach out to me in the past and I'm pretty sure they are working (as AML analysts) now. I can't say them reaching out to me directly helped, but perhaps them mentioning me helped to validate their education or helped them use the right vocabulary.
From a Senior Associate in AML/Due Diligence at a large commercial bank: Not all AML jobs are created equally. There are different positions for monitoring transactions and reporting suspicious activity, conducting due diligence on customers before account opening and positions for writing AML/KYC policy.
I would recommend getting extremely familiar with Excel and manipulating databases. AML/KYC is completely metric driven. Senior management and the regulators don't want novels on the status of AML/KYC efforts. They are looking for a quick report with Key Risk Indicators based on data extrapolated from whatever database/case management system is being utilized. Employees that get promoted faster than others were assigned to special reporting projects because they know how to gather that data, analyze it and package it in a clean, easy to use format.
Lastly, I would recommend that students serious about entering into the field pursue the Certified Anti-Money Laundering Specialist (CAMS) certification. It's an industry standard and is often a prerequisite for employment. It's somewhat expensive, but students do get a discount.
From a Vice President-AML Compliance at a large multinational bank: Not all AML jobs are the same. There are very different levels of focus / responsibility / and potential career growth between different organizations and within different departments. Know what you’re getting into in terms of the work and apply to a position that aligns with your interests.
Interviewers are very interested in whether applicants can think in an independent / logical / creative way. When I was interviewed, the last question I was asked was “how many toasters are there in Phoenix?” (Ed. Note: See Fermi Questions) I ask similar questions when I interview people (although they’re directly related to the job and not household appliances). When you get these types of questions – do not answer them immediately, ask your interviewer questions or tell them about what you're assuming about the question before you answer it. It buys you time and you will give a better overall answer. In every answer that you give stress critical thinking and walk people through your thought process. Develop financial analysis skills in school. Even if you’re not interested in AML work – financial analysis skills are HIGHLY marketable and will help you land a job.
From an AML investigator with a large multinational bank: I feel that a class that provides a good comparison to how investigations are approached by successful AML investigators would be Professor Grabelski’s Into to Law Enforcement Intelligence. I’m sure I am not alone in remembering him drive this investigative notion home: “Tell a story!”
Q: There seem to be many different names for this job (depending on the institution). What are some of the search terms people should use to find these jobs?
- AML Investigator/Analyst, Compliance Officer, BSA/KYC Analyst, Global Financial Crimes Analyst/Investigator, Financial Investigative Unit (FIU) Analyst/Investigator
- Look for jobs that include alphabet soup acronyms such as KYC, AML, BSA, OFAC, USA PATRIOT Act, and other topics such as fraud and compliance.
- The search terms I would utilize the most (it can change between banks) would be "Compliance Officer", "AML/BSA Officer", and "Analyst". Trying different combinations of those terms should help, but naturally read the job descriptions to make sure your credentials apply.
- Students should use the following search terms when trying to find these types of jobs: AML, KYC, due diligence, OFAC, SAR (a lot of job descriptions involve suspicious activity reporting), BSA and PATRIOT Act. Some AML investigator positions are also called "Compliance Analysts.”
- Search terms for AML jobs: ‘money laundering’, ‘AML’, ‘BSA’, ‘compliance’, ‘investigations’, ‘suspicious activity report’, ‘SAR’, ‘bank secrecy’, ‘OFAC’, ‘fraud’, ‘typology’
Q: What are the opportunities for hiring right now? What about for promotion and for movement within and between institutions in the future? Is there anything else we should know?
From a Vice President-AML Compliance at a large multinational bank: I think there are a couple reasons people have gravitated toward AML: 1) The market is very hot right now. There are more AML jobs out there than there have been at any point in the past. 2). Because there are more open vacancies it’s becoming tougher for organizations to find qualified people and that’s led to a significant increase in overall salaries in the past couple years. 3) You can get an AML job in virtually any city in America. That’s an attractive option for people who don’t want to live in DC or other areas where intel jobs are traditionally clustered.
From an AML Compliance officer/Analyst with a large multinational bank: As the demand for these positions increases, banks and related financial institutions will give away some of the negotiating power to the candidates, which is good for recent grads. I'd advise NOT to low-ball your worth. Many of the open positions will list a salary range.
There is A LOT of poaching that takes place. Many people from our team have left to go to X, where they are getting paid more than what they would have gotten if they stayed here (from what I was told). And it seems we hire from X, probably offering more then what they would have got if they stayed! Location does matter, so evaluate the cost of living too. It is a bit odd to me, but it seems to be the status quo. People usually stay in a position for 2-3 years and move internally or externally. So, job mobility is definitely a plus, but it may be required (or encouraged). Once you have been at a bank for a bit your marketability increases as well if you want to go to a different bank, which is good job security.
I created an entry-level Intel focused group here on LinkedIn back when I started out. With minimal effort on my part, there are now 1,216 members, many asking the right questions and even job postings from myself or others. It is called "Entry Level Intelligence Analysts".
From an AML investigator with a large multinational bank: I feel that Mercyhurst’s reputation is growing in the private analysis/investigative sector at a fast rate. A lot of investigators and management come from public sector jobs in DC, where I feel that our reputation was already strongly solidified. Now that reputation is transferring over to the private sector…I know that within my organization Mercyhurst’s reputation for producing good analysts was already established when I got here…recent Intel grads have been so successful within the past year and a half many of us have been selected for managerial roles overseeing investigation teams.
From a KYC Analyst at a large multinational bank: There is, in my opinion, a significant opportunity for mobility within the organization, including internal hires from and to other departments.
From a Compliance Analyst at a regional bank: Even if there are no upward promotions available right now (as teams and supervisors are set for the time being), there is the opportunity to do other roles, and thus gain more experience to be more competitive for promotions.
That's it! Lots of good advice and insights into what could be an interesting (and well-paid) career in intelligence in business. I am certain there are many more readers who have their own tips or ideas concerning such a career choice. Please do not hesitate to leave a comment!
