Do more with less! How ACAMS Helps Banks Strategically Respond to Cost Optimization with Customized AFC Cross-Training to Avoid Past Failure Patterns.
Meaghan Penido Burnier (Wood)
A problem well-stated is a problem half solved.
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Crafting a way to do more with less without eroding outcome quality is the reality for anti-financial crime leadership in banking. With strides in generative AI at the center discussions, pressure mounts to 'automate' as much AML workload as possible. As AFC leaders looking to free up bandwidth to focus on "needle-moving" effort, there's a glaring AML talent gap to mitigate massive regulatory action risk.
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During the ACAMS Sanctions & Compliance Assembly in South Florida last week, Daniel P. Stipano from Davis Polk & Wardwell LLP took a page from Bill Shakespeare and shared an insightful quote that may paint the story best for banks when considering how they'll approach their AFC go-forward approach :
"Past is prologue.... If banks focus solely on soundness & safety, they may take their eye off the AML ball."
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This pressure could materially elevate enforcement action risk given other environmental headwinds such as:
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-Finance workforce resignation trends
-Tech modernization pressures
-Unstable deposit fluidity
-Geopolitical sanction tension
-Low public approval ratings for banking sector
-Skyrocketing interest rates
-Less-than-ideal regulatory guidance/clarity
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Recognizing L&D isn't any bank's core proficiency, many AFC leaders are seeking a trusted partner like ACAMS to navigate these material AFC headwinds as they look to mitigate enforcement action risk akin to '07/'08.
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So, 'what to do about everything?' (Yes, my 2nd Shakespeare reference for those counting at home!)
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Option #1 --> DIY:
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One potentially near-sighted cost-optimization trend we see emerging focuses on insourcing AFC learning & development, but this will cost AFC leaders. To channel another assembly panelist, Patricia Sullivan from Deutsche Bank, creating a compliance culture isn't a "year-one" type of investment.
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"Compliance leadership must be able to garner long-term board confidence and support to create & protect a sustainable compliance culture."
While cost reduction mandates go hand-in-hand with banking downturns, banks making short-sighted, siloed changes to an AFC program is not a sustainable go-forward either.
This is why our global banking partners are proactively approaching ACAMS to better understand how we can help them navigate.
Worth consideration:
When considering DIY, banks need to ask themselves, "How well-positioned (and resourced) are we to deliver all the necessary AFC L&D content in a timely way during such a massively disruptive, regulatory fluid market downturn?"
Option #2--> Cross-training :
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Instead, many banks are leaning into cross-training initiatives aimed at enabling teams with increased scopes of AFC knowledge required to deliver more strategic outcomes that resonate with regulators as well as the dollars & cents reality of fighting for budget in a cost-optimization climate.
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Unfortunately, most banks have material AFC talent gaps when considering internal L&D programming. Yes, no doubt there is quality internally-generated content out there, but in the face of tightening belts and rapidly-evolving regulatory complexity, many fall short with outdated content and disheartening ROI according to a recent Harvard Business Review:
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??Did you know an average bank expends 125 hours for every (1) hour of compelling L&D content it creates?
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Option #3 --> Strategically leverage ACAMS' Enterprise-level AFC L&D solutions for accretive cross-training initiatives.
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Many AFC leaders are confronting tough realities like, "Where & how do we most effectively partner, budget, & resource allocate with internal learning groups in context of this sort of 'juice -vs- squeeze' ROI dynamic?"
Good news is ACAMS can help.
With customized AFC L&D solutions co-created with the largest, most complex financial service partners in the world, we're helping bank partners shore up risk & bridge capability gaps in cost-effective ways so they can safely, securely, and profitably develop the highly-trained AML professionals required for today's new normal.
-Meaghan Wood
ACAMS, Director - Key Global Banking Partnerships