As noted in my first post on this topic, financial firms face real challenges in building and maintaining strong anti-money laundering and know your customer (AML/KYC) programs, not to mention cultivating good AML/KYC talent in the workforce. Our paper, Anti-money Laundering and Know Your Customer Programs: Sustainability through Managed Services, and the presentation that accompanies it, gives in-depth detail around what faces financial enterprises, and steps them through some of the available solutions. Likewise, our paper, Leveraging Enhanced Talent Development Programs to Increase Anti-Money Laundering Workforce Effectiveness, outlines approaches focused on the talent part of the AML/KYC equation.

Read the report

But before we can dive into solutions, shouldn’t we understand the challenges and the barriers that are in the way? From regulatory burdens, talent shortages and obstacles around growing talent, much may need to be overcome before a financial firm can build a truly solid AML/KYC approach.

As our supporting presentation notes, unsustainable processes (including reliance on manual effort, extensive simplification and poor understanding of a process’s complexity) and insufficient quality (insufficient metrics, issues with sampling calibration and lack of continuous improvement) combine with talent challenges to present businesses with a doubly bad headache.

Arguably, skilled talent underlies all of these concerns. But organizations are finding it difficult to build and deploy strong AML/KYC learning programs at the required scale. Those firms that have tried “growing their own” AML/KYC workforce have encountered obstacles:

  • In many organizations, the learning function is decentralized, making it that much harder for content to keep pace with regulatory change.
  • Spending around learning is not always keeping pace with headcount increases.
  • The saturated market can make it harder to hire specialized talent.
  • Role-based training and continuing education are not sufficiently emphasized.
  • Training strategies may be outdated, and the processes by which they are updated are not keeping pace with regulatory and industry change.

For some organizations, addressing these gaps in training capabilities and, thus, building home-grown AML/KYC talent, may be out of reach. Maybe it’s time to consider some alternative solutions?

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