Specialty Certification

Objectives of the Anti-Money Laundering Certification Program:

• To achieve recognition of the skill level required for the examination of adherence to Anti-Money Laundering / Countering the Financing of Terrorism (AML/CFT) laws and regulations applicable to regulated financial institutions and money service businesses.
• To emphasize the need for professionalism and continuing advancement of AML/CFT examination professionals given the specialized skills and knowledge necessary to adequately supervise this area.
• To develop and master regulatory framework and legal requirements for AML/CFT with special emphasis on:

  • Risk assessment skills

  • Customer Due Diligence (CDD) and Know your Customer (KYC) protocols, and   

  • Detecting suspicious activities   

• To promote continuing education in the AML/CFT area of examination through training and understanding emerging trends and preventative measures.

Candidates for Certified Anti-Money Laundering Specialist designation must provide evidence of each of the following:

• Completion of 2 years’ experience of on-the-job service and training as an examiner.
• Possesses the skills and experience required to serve as the lead AML/CFT examiner.
  • Participated on a minimum of 10 AML/CFT examinations with at least 2 of those being large, complex, or high-risk institutions. Served as lead AML/CFT examiner on at least 5 examinations. Satisfactory completion of the following sections of the AML/CFT Work Program

    • AML/CFT Risk Assessment

    • Assessing the AML/CFT Compliance Program

    • Developing Conclusions and Finalizing the Examination

  • Has completed all sections of the AML/CFT Work Program, including transaction testing on three examinations
• Satisfactory completion of the following courses or an equivalent course (courses submitted for equivalency will be considered on a case-by-case basis):
  • Day One: BSA/AML Examiner Training
  • AND at least 28 hours of advanced AML/CFT education including course offerings such as:

    • CSBS BSA/AML Examiner School

    • FFIEC Anti-Money Laundering Workshop

    • Advanced Bank Secrecy Act/Anti-Money Laundering Specialists Conference (BSA/AML)

• Attestation of successful job performance and mastery of appropriate job-related skills by the candidate’s immediate supervisor or other senior employee who is familiar with the applicant’s experience, performance, and skills and abilities. The supervisor or other qualified individual must attest that the applicant meets or exceeds expectations regarding all competencies listed below and the examination requirement.

The attestation form addresses the following categories:

TECHNICAL - Provides effective leadership and organization to the examination process:

• Demonstrates knowledge of the Bank Secrecy Act, Homeland Security Act and other AML-related policies, procedures, laws, rules and regulations
• Demonstrates effective skills to plan and organize examination/investigation functions
• Oversees personnel to ensure adherence to examination procedures and policies and progress of work completion related to the AML/CFT review, where appropriate
• Participates in/leads the development of the examination plan where appropriate
• Effectively follows established examination policies and procedures
• Actively participates in all phases of on-the-job AML/CFT training of other examiners
• Effectively documents results of analysis in written comments that are factually and technically correct, with appropriate conclusions, and proper grammar
• Documents support for the report of examination with detailed information and provides a clear audit trail in workpapers
• Organizes and effectively documents workpapers according to prescribed procedures

CONCEPTUAL - Provides effective and accurate evaluation of the overall activities of financial institutions/money service businesses relating to AML/CFT:

• Demonstrates ability to identify risks to the institution in the areas of AML/CFT
• Demonstrates ability to lead, guide, and follow examination procedures to collect and analyze data
• Monitors and tracks outstanding regulatory issues and analyzes progress or resolutions
• Effectively evaluates and recommends adjustment of scope of the examination as the situation requires
• Develops correct conclusions from collected data
• Demonstrates an understanding of the BSA/AML Work Program; should be proficient in all procedures through and including Assessing Compliance with BSA Regulatory Requirements and knowledge of the additional sections
• Demonstrates in depth knowledge of the FFIEC BSA/AML Manual
• Demonstrates the ability to write findings and cite the appropriate violations of laws and regulations such as Suspicious Activity Report (SAR) filings and compliance reporting to internal management, involving accurate documentation, understanding of legal protections, and regulatory obligations
• Demonstrates competency/understanding relative to the concepts of the Five Pillars of BSA, AML/CFT  Risk Assessment, Customer Identification Program (CIP), Know Your Customer (KYC)/Customer Due Diligence (CDD)/Enhanced Due Diligence (EDD), Currency transaction reporting (CTR) and CTR exemptions, Purchase and sale of monetary instruments recordkeeping, funds transfer recordkeeping, foreign correspondent account record keeping and reporting, foreign bank and financial accounting reporting, OFAC examination and review procedures and requirements, and AML/CFT and OFAC recordkeeping requirements.
• Knowledge and experience with large, complex, and/or high-risk institutions AML/CFT

LEGAL/COMPLIANCE - Effectively demonstrates knowledge of policies, procedures, laws, rules and regulations.

• As applicable, serves as a Subject Matter Expert of AML/CFT related examination areas
• Assesses risk management framework/processes and determines adequacy in relation to best practices and regulations in relation to the risk profile of the bank
  • Assesses compliance with those approved frameworks through effective transaction testing
• Current knowledge of Statutes and Regulations detailed on fincen.gov such as Bank Secrecy Act: USA PATRIOT Act, OFAC, FinCEN Special Measures, and reviewing for compliance with AML/CFT enforcement actions. 
• Current knowledge of state specific rules and regulations related to AML/CFT

COMMUNICATIONS - Provides effective oral and written communications:

• Effectively and clearly communicates assignments to other examination personnel where appropriate
• Effectively and clearly communicates with financial institution/money service business management/personnel and third-party service providers to obtain information
• Effectively and clearly communicates examination findings and violations to lead examiners and financial institution management
• Effectively prepares written comments which are accurate, grammatically correct, logically arranged, and factually support examination conclusions
• Presents logical supporting arguments in response to any management objections and moderates own conclusions if presented with sufficiently supported data by management
• Effectively conducts meetings with management and/or the boards of directors in an organized and professional manner
• Recommendations and ratings demonstrate a thorough and successful understanding of regulations, statutes, and directives as applicable to the entity under examination/inspection
• Inspires the respect and confidence of others, including Federal counterparts and institution management
• Effectively enhances interagency collaboration with law enforcement and other regulators in combating financial crimes, sharing insights and intelligence to prevent money laundering and terrorist financing.

Anti-Money Laundering Specialist Recertification

Every three years, participants will be required to provide evidence of the successful completion of a minimum of 40 continuing education hours (CEHs). Examples of qualifying programs and activities are listed below. Other programs and activities submitted will be considered on a case-by-case basis per the continuing education policy.

Certified Anti-Money Laundering Specialists should be registered with the FinCEN Newsroom to remain current on AML/CFE requirements.

The following are approved continuing education options:

• Applicable portions of Annual Conferences or other training provided by:
  • CSBS
  • MTRA
  • AARMR
  • NACCA
  • NCUA
  • Federal Agencies
  • FFIEC
  • ACAMS
  • ABA