ACAMS Today had the opportunity to sit down and ask three of the ACAMS Advanced Financial Crimes Investigations Certification (CAMS-FCI) developers what it is like to be a financial crimes investigator today and how it has evolved over time. Learn from Dave Dekkers what the biggest hurdle financial crimes investigations professionals' face, the importance of training from Kate Salottolo, and how technology affects investigations in this day and age from Michael Amo.
Dave Dekkers, CAMS-Audit is an expert with regards to fighting financial crime, working for either financial institutions or vendors who deliver solutions to the finance industry. Dekkers' passion for working in the fighting financial crime field is because it is challenging, exciting and a constantly changing environment with equally passionate community members.
Dekkers is an independent consultant focusing on delivering services and solutions to assist in the fight against financial crime. His duties include setting up or improving compliance and/or fraud teams, auditing procedures and revamping sanctions, anti-money laundering (AML) and fraud controls and programs at financial institutions. Dekkers is actively involved with startups where he combines his expertise with new groundbreaking methodologies/software to further assist financial institutions.
ACAMS Today: How has the face of financial crimes investigations changed over the past five years and what changes do you foresee on the horizon?
Dave Dekkers: In the last five years tax evasion quickly became part of investigation work as well, which is again a difference in what was done before. New regulation makes the scope and breadth of activities much more complex and time-consuming and without the proper means or approach this might lead to extremely high costs for financial institutions (FIs).
Changes that are foreseen on the horizon are that financial crime investigations are only getting more complex. Investigators will have difficultly not only fighting the sheer amount of work, but also the complexity of investigations. Therefore, investigations based on alerts and case management systems are going to be a thing of the past. To handle the workload, more advanced and complex analytics are needed and financial crime departments will need data scientists and tools to weed out the clutter and help investigators to focus on the actual activities at which investigators will look.
AT: What is the biggest hurdle financial crimes investigations professionals' face today?
DD: The sheer load of work (read alerts and legislative changes, new types of crimes and responsibilities) and the increasing complexity in investigations. When you ask an investigator what he or she needs to do their work, their answer is enough of the right information. But what is the right data (hurdle 1) and is that data subject to privacy laws (hurdle 2).
AT: What part does technology have in streamlining investigations?
DD: Technology can only streamline investigations in a productive manner, if we automate those activities that cause investigators a lot of work. Investigators who understand the business and their job, will only need the relevant information to make a quick decision. Our technological means should provide this relevant information, so that investigators can become more efficient and can focus on making the right decisions.
AT: Do you have to be an investigator to conduct investigations?
DD: There is not just a profile of an "investigator" that is a one-size-fits-all, if you work on a team you need to have differently trained and skilled staff to get the best results. A data analyst is not directly quantified as an investigator, although they are great at finding anomalies. To merit anomalies you need to have people with either product or customer knowledge.
So, an investigator is anybody that can spot anomalies and/or merit the anomalies against what is normal and expected. The proven anomalies will provide the right facts to search further and to build out an actual investigation.
AT: Do you have to be ex-law enforcement to be a good investigator?
DD: That is a very interesting question. I have asked myself this question quite often in the past, and since a couple of years ago I can quite confidently say "no." But it is a "no" with some extra remarks, as it is the combination of people thinking slightly different that allows for breakthroughs in investigations. Some years ago we were working with a small team of experienced ex-law enforcements agents, some visualization experts and a couple of data miners and during the sessions we had together we were able to help each other to step over/resolve typical problems that we run into if we work with similarly trained investigators/experts. Needless to say, we were able to create very interesting insights into criminal investigations.
A good investigator needs to be open-minded
A good investigator needs to be open-minded, being able to reinvent himself/herself and not to be afraid to try a different method of solving a problem. And what many people often forget: use a pen and paper and draw!
Kate Salottolo is a director in the Financial Intelligence Unit (FIU) at American Express where she oversees the Impact Assessment program, which includes ensuring alignment across the various teams within the FIU through the analysis of management reports and inventory strategies, as well as the ongoing assessment of new program initiatives that relate to the overall AML monitoring and reporting process. This includes forecasting the impact of various projects on the investigative process, including new transaction monitoring rules, changes to investigative procedures, system enhancements, and other efficiencies and proposed enhancements.
Prior to her current role, Salottolo was a manager in the Strategic Investigations team where she managed a team of analysts, coordinated complex investigations, assisted with the development of new monitoring rules and conducted training focused on best investigative practices for new employees. While overseeing the Strategic Investigations team Salottolo also worked closely with law enforcement to enhance the intelligence in long-term investigations.
Prior to joining American Express in 2009, Salottolo worked as an investigative analyst at the New York County District Attorney's Office for three years, assisting prosecutors in the investigation of a variety of cases, including homicides, robberies and identity theft, among others. While working, Salottolo attended New York Law School where she served as a law review staff editor, earning her J.D. in May 2011.
AT: What efforts are being made to enhance collaboration between law enforcement and financial institutions in regards to investigations?
Kate Salottolo: Law enforcement and financial institutions are starting to participate in regular forums where leaders in the financial crimes/AML space come together with law enforcement to discuss recent trends and to share information at a high level. These efforts ensure that both sides are aligned on the current environment, and that financial institutions (FIs) are aware of relevant focus areas for law enforcement and vice versa. I also think that law enforcement is becoming more aware of the value that FIs can provide, partially because of these collaborative forums, and partially because suspicious activity report (SAR) filings and the accompanying supporting documentation are becoming more sophisticated. The advanced technology and data analytics used by financial crimes investigators today puts FIs in a better position to build and maintain relationships with law enforcement.
AT: What advice can you offer someone looking to transition into financial crimes investigations?
KS: I would advise someone looking to transition into financial crimes investigations to educate themselves on the current legal and regulatory environment, and to familiarize themselves with money laundering and fraud typologies generally. I always encourage people interested in this field to become familiar with ACAMS and to visit the FinCEN website with a focus on the "News Room" and "Statutes & Regulations" sections. Setting Internet alerts is also an easy way for aspiring financial crimes investigators to stay on top of relevant developments in the industry. Finally, it's important for people seeking careers in financial crimes investigations to think about the totality of their skill set. For example, most financial crimes investigators are not just investigating and identifying potentially suspicious activity, but writing about their findings in memos and/or SARs. Oftentimes the writing component is just as important as having a keen investigative eye.
AT: What are the key components of a sound financial crimes investigations unit?
KS: A sound financial crimes investigations unit has the following foundational elements: (1) A solid training program and comprehensive investigative procedures; (2) uninhibited access to transactional data across product/business lines; (3) a well constructed and adaptable case management system; and (4) a robust transaction monitoring rule program.
AT: What is the importance of training for financial crimes investigators?
An effective training program is critical for developing skilled financial crimes investigators
KS: An effective training program is critical for developing skilled financial crimes investigators. If issues, questions and logistics are not addressed in training, quality and efficiency suffer from the onset. Training is also the ideal setting to establish the overall messages that are critical to an investigations program. This is the forum to lay the groundwork for the importance of the work, the sensitivity of the data, and the expectations for quality and consistency.
AT: If you had an investigations wish list, what would be on it?
KS: The ability to instantly retrieve all internal and external data across products, business lines and markets through a single platform would definitely be on this list.
Michael Amo, CAMS is currently supporting Promontory Financial Group in a variety of regulatory and compliance functions at international and domestic financial institutions with a specialization in transaction monitoring, risk assessment, know your customer (KYC) and training.
Prior to working with Promontory, Amo consulted on behalf of several international banks under varied degrees of regulatory oversight and provided a range of subject-matter expertise with an emphasis on correspondent banking.
Amo has amassed a solid foundation of financial services and banking experience throughout his career and attained professional licenses in every field including most recently, the CAMS designation. He is also a member of the content and grading evaluation committee for the ACAMS CAMS-FCI advanced certification program and holds a bachelor's degree in finance from the University of Florida.
AT: What qualities should a great investigator have?
An investigator's job is crucial to the business
Michael Amo: A great investigator should be tenacious, curious yet focused, open-minded and versatile in order to perform at their highest level. Particularly in AML, an investigator's job is crucial to the business and often with few leads available, it is imperative to maximize your abilities. Prioritizing your work will help ensure an intelligent approach for each circumstance and give you the blueprint to succeed.
AT: What part does technology have in streamlining investigations?
MA: Technology will continue to play an ever significant and evolving role in AML investigations. The explosion of social media and Internet resources has made it increasingly difficult for individuals and businesses to remain anonymous. Sophisticated data analysis platforms like Palantir and Actimize are vital for consuming massive quantities of data by leveraging analytics and modeling techniques to uncover anomalous financial transactions and complex relationships.
AT: What industries would benefit from enhancing their financial crimes investigations?
MA: Costs for Americans to comply with federal regulations reached $1.863 trillion in 2013, which is more than the GDP of Canada and Australia. As the world evolves and regulation attempts to keep pace with emerging trends and technologies, those industries not in the crosshairs today will be tomorrow or soon after. If you were attempting to avoid detection, wouldn't you utilize marginalized 'low-risk' financial products or obscure businesses? To that end, money launderers will continue to exploit breaches in the AML infrastructure, which will ultimately force less regulated industries to enhance controls and oversight.
AT: What advice can you offer someone looking to transition into financial crimes investigations?
MA: When I began my career in financial crimes investigations, I surrounded myself with seasoned colleagues and asked a lot of questions. In AML, it is remarkable to me how one person's perspective can be polar opposite from another, yet not necessarily wrong. Find a mentor or two that you trust, believe in, and that are willing to spend the time to build your confidence and skill set.
AT: What are the regulators asking financial institutions to do in order to improve their financial crimes investigations/financial intelligence units?
MA: A more appropriate question might be, "What are the regulators not asking for!?" But seriously, over my career I've had the opportunity to engage with numerous highly visible and diverse financial institutions under various degrees of regulatory oversight. The extent of complex and comprehensive monitoring methods and controls regulators now require of industry leaders is immense and varies dependent on business type, but since generally no piece big or small is overlooked it necessitates a FIU to stay ahead of the curve in all aspects of technology and subject-matter expertise.
