Page 33 - GS210601

Education

AML tools ISOs are on the team that fights financial crime. Basic investment in policies,
tools and training in support of that fight is good for security and good for
Wait, is there an app for that? The business because bad apples can cause processors and their ISOs a lot of harm.
automation of certain key AML func-
tions, such as screening merchant
owners against SDN lists and certain
aspects of transaction monitoring, In publishing The Green Sheet, neither the author nor the publisher is engaged in rendering legal,
is now the norm. A number of third accounting or other professional services. If legal advice or other expert assistance is required,
parties supply screening and moni- the services of a competent professional should be sought. For further information on this article,
toring services that are superior to please contact Adam Atlas, attorney at law via email at atlas@adamatlas.com or by phone at
any manual effort. As merchants or 514-842-0886.
their activities are flagged, however,
human intervention is often required
to make decisions about the activity
in question.

AML training
Any individual involved in managing
AML risk deserves (and indeed re-
quires) suitable training for the task.
Just like training a sales agent on sell-
ing merchant services, the process of
screening and monitoring merchant
activity requires unique skills that
need to be learned.

AML training is readily available
from a number of sources. The lead-
ing AML accreditation is the ACAMS
certification (www.acams.org). Given
that all payments professionals de-
serve professional enrichment, train-
ing in AML is a good idea even if you
are not managing that task within a
business.
The amount of training recommend-
ed is commensurate with the degree
of responsibility a person has.

Privacy and security
Fun fact: It is illegal to inform the
subject of a SAR that a SAR has been
filed on them. This, and the fact that
merchant and transaction monitoring
often involves non-public personal
information, means that the AML
function must be done with caution
and with extreme prudence regard-
ing privacy and security.

An AML program is not a public
document. It is an internal and con-
fidential document that should not
be shared outside of the payments
institution. One reason for this is that
you would not want to give bad ac-
tors a recipe for circumventing AML
controls.
33