A few months ago we began to notice an interesting transformation in the way the Association of Certified Anti-Money Laundering Specialists (ACAMS) events/courses were being advertised on digital platforms such as LinkedIn:

“Annual Latin American Conference on AML and Financial Crime”.

To strengthen the introductory argument I intend to make in this article, and before delving into the example of ACAMS, it is also necessary to turn our attention to the Association of Certified Financial Crime Specialists (ACFCS) which, although it does not have the same trajectory as ACAMS, has managed to position itself with a market niche that seeks to expand its study horizon beyond the traditional focus of the Prevention of Money Laundering and Terrorist Financing (AML/CFT).

So what patterns of change or “innovation” can be detected in the way LDP/FT professionals have evolved, and thus the organizations that represent them (ACAMS, ACFCS)?

Everything seems to indicate that both ACFCS and ACAMS have detected that the initial challenge of AML/FT evolution is to holistically address and study the different faces of financial crime, something that the International Compliance Association (ICA) has also addressed since its origins.

The financial crime focus landscape consists of at least the following areas of specialization:

  1. The specialization and study of the phenomenon of money laundering continues, providing more and more tools for analysis and study of its multiple predicate offenses. The trend is focused on forensic analysis, investigations, robust reports, cooperation, and assisting the competent authority in the recovery of assets.
  2. The study and understanding of the phenomenon of terrorism is further innovated and awareness of the threats that terrorism poses to world peace is raised.
  3. The study of the international legal framework (often taking the UK Bribery Act [UK Bribery Act], or the US Foreign Corrupt Practices Act [FCPA]), local, as well as best practices (ISO 37001) to combat bribery and corruption, without neglecting that the human understanding of what behaviors encourage these offenses is vital. [FCPA), local, as well as best practices (ISO 37001) for the fight against bribery and corruption, without neglecting that the human understanding factor about which behaviors encourage these illicit acts is vital for a frontal attack.
  4. The increasing expectation of regulatory compliance in relation to international sanctions (or Embargoes) such as the Office of Foreign Assets Control (OFAC), Her Majesty’s Treasury (HMT), the European Union, United Nations, Hong Kong, etc.
  5. Tax evasion has received increased attention from groups such as the International Consortium of Journalists and Investigators (ICIJ) through cases such as the Panama Papers, Bermuda Papers, etc.
  6. Internal fraud by employees, or threats from the organization’s own customers.
  7. Cybercrime, which needs to be understood in depth, as well as cybersecurity threats that should be part of a robust compliance program, a theory yet to be substantiated.

In addition to the areas of Financial Crime Compliance (FCR), we must not forget the vital elements that regulate other types of regulations, such as: Data Privacy, Competition and Market Rules (Market Abuse), Consumer Protection, among others that vary depending on the type of organization on which the compliance function is implemented.

This gives rise to the challenges of making the CDF the new focus for compliance, as the level of specialization required is immense, not to mention the personal risks for the person wishing to serve as a Compliance Officer with the full range of responsibilities mentioned in this opinion.

At the same time, let’s also not rule out that this level of specialization is possible, fostering a more armed and prepared class of Compliance Officer in Mexico and the world, with a view towards a #DisruptiveCompliance.