AFC Superhumans: Filling Job Market Gaps – ACAMS Today

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Top financial institutions (FIs) are seeking a new breed of anti-financial crime (AFC) professionals—those who can seamlessly integrate advanced technological skills with traditional compliance expertise while maintaining a human touch.

These “AFC superhumans” possess a unique blend of technical acumen, interdisciplinary knowledge and intangible soft skills that set them apart as industry leaders. They not only understand the intricacies of AFC and anti-money laundering (AML) but are also adept at harnessing the power of artificial intelligence (AI).

As FIs lean on technology to combat financial crime, demand is rising for AFC professionals who can bridge the gap between traditional compliance skills and modern technological capabilities.

This article (part one of a two-part series) discusses the next generation of financial crime prevention skills and offers steps to facilitate career growth in an AI-driven era. By examining how these emerging skills are being redefined and why they matter, AFC professionals can uncover hidden opportunities and fill talent gaps in a transforming job market.

The guidance herein is catered toward U.S.-based regulated FIs that have global operations.

A Hard Look at the Future of Skills

Traditional AFC competencies—such as those relating to policies and procedures, regulatory knowledge and a deep understanding of the key pillars of an AML/sanctions program, including internal controls1—remain the “gold standard” for AFC professionals.

However, as the field evolves, the following expectations are becoming increasingly important:

  1. Technical skills, particularly AI and data analytics
  2. Interdisciplinary knowledge across functions and processes
  3. Expertise in emerging areas, especially those emphasized in regulatory updates

Technical Skills: AI and Data Analytics

In May 2024, the U.S. Department of Treasury shared an important message:

“Innovations in AI, including machine learning and large language models such as generative AI (GenAI), have significant potential to strengthen anti-money laundering/countering the financing of terrorism … compliance by helping financial institutions analyze large amounts of data and more effectively identify illicit finance patterns, risks, trends, and typologies.”2

The AFC sector is embracing this invitation to explore the digital age by investing heavily in AI and data analytics technologies.3 This comes in the form of learning about, experimenting with and integrating advanced technology to improve AFC operations. AI is used to assist with the following:

  • Accuracy (e.g., reduce errors by standardizing processes and learning from data)
  • Adaptability (e.g., adjust swiftly to new patterns and emerging threats)
  • Efficiency (e.g., automate repetitive tasks to use resources more effectively)
  • Scalability (e.g., handle large volumes of data that are impractical to process manually)4

Table 1 below provides a glimpse of potential AI applications across various AFC functions:

Source and visualization by: Natfluence, Jon Estreich, CAMS-Audit, CFE5

The far-reaching benefits and use cases of AI, including the responsibility to “safely innovate,” means that understanding the role of technology, and its associated risks, is no longer confined to data-centric positions but extends to all AFC professionals.6

Large language models (LLMs), like ChatGPT, have democratized access to advanced technologies, setting new standards for AI proficiency throughout the AFC community. These tools close the divide between highly technical AI applications and everyday professional use, emphasizing the value of foundational AI skills for professionals at all levels.

Nadia Leonova, global anti-corruption and financial crimes director at Deloitte, points out the need for human intervention and oversight when using these tools, stating, “It’s crucial to remember that any AI-produced output requires critical analysis by trained AFC professionals to ensure the relevance, applicability and successful operationalization of results.”

Professionals who grasp AI tools and their safe implementation are better positioned to lead initiatives that integrate new technologies into existing systems. This includes the ability to:

  • Determine resources and expertise required to adopt advanced technologies
  • Recognize areas where AI can significantly enhance compliance functions
  • Explain to stakeholders how AI technologies contribute to AFC efforts

Proficiency in these areas helps professionals execute their roles more effectively and deliver insights that guide the strategic use of AI within their organizations. It also aligns with the ongoing digital transformation in the AFC industry and renders them invaluable assets to their teams.

The following are three ways to build AI and data analytics awareness without a technical background:

  1. Study machine learning concepts: Understanding machine learning can help professionals interpret model outputs to make informed decisions about potential risks or suspicious activity. For instance, familiarity with “feature importance” in machine learning models can help to identify which aspects of a customer’s behavior contributed most to a risk score.7
  2. Obtain prompt engineering skills: Savvy chat prompting can facilitate data analysis, enhance research capabilities, automate reports, streamline routine tasks and support decision-making. As organizations launch proprietary chatbots, making them accessible within the confines of their infrastructure, employees who can optimize interactions with LLMs will have an upper hand.
  3. Learn about responsible use of AI: Encouraging innovation through a culture of governance and oversight—including adherence to ethical standards—is increasingly important. Organizations like the Financial Conduct Authority, the Canadian Government and the Financial Action Task Force (FATF) offer tool kits and resources on AI governance, risk management, regulatory compliance, quality control and planning.

Interdisciplinary Knowledge Across Functions and Processes

FIs are searching for AFC professionals with diverse expertise, skills and knowledge that span multiple AFC functions and processes.8

The demand for versatility is driven by several factors, including:

  • Industry transformation: Stricter regulations and significant changes across the AFC landscape require substantial resources for financial crime prevention efforts.
  • Novel and complex threats: The emergence of sophisticated and multidimensional financial crime risks requires agile and specialized staff who can pivot quickly.
  • High costs and limited supply of resources: Barriers in onboarding talent require FIs to optimize existing staff by retaining a multiskilled workforce that is adaptable.

Professionals with diverse skills, experiences and perspectives across AFC can tackle a larger variety of complex financial crime tasks and fill vacancies where needed.9 This resourcefulness combined with the ability to collaborate across functions (e.g., transaction monitoring, know your customer, sanctions screening) and departments (e.g., legal, operations, internal audit, compliance) contributes to a nimble and efficient workforce.

Top FIs, therefore, value AML/AFC professionals who:

  • Have a strategic understanding of emerging risks
  • Can implement innovative, risk-based approaches
  • Can collaborate seamlessly across functions and departments
  • Are deeply versed in regulatory subtleties and the impact of recent changes
  • Are adept at navigating the intricacies of new financial instruments and technology

For FIs with global operations, these traits, along with knowledge of both domestic and international regulations, are essential. However, what separates one AFC professional from the next is the ability to foresee—and prepare for—the impact of impending regulations and emerging risks. This foresight often requires a holistic view and multifaceted perspective.

“As the financial crime landscape evolves and grows more complex, the ability to effectively work across multiple disciplines, combining different types of expertise, becomes a key attribute setting apart top industry professionals,” noted Leonova of Deloitte.

Expertise in Emerging Areas

Regulatory communications in 2023 and 2024 spanned industries, geographies and customer types. From guidance to new rulemaking, AFC professionals at regulated FIs in the U.S. and the EU had an abundance of information to consider for potential integration into their programs and processes.

Over the past two years, there have been ongoing updates to the FATF Recommendations, expansions in U.S. and EU sanctions regimes, broadening of AFC regulations to additional business sectors and comprehensive amendments to AML directives.

Concurrently, industry focus has intensified around combating fraud, particularly cyber-enabled financial crime, and ensuring that emerging technologies like AI are incorporated ethically and effectively into compliance frameworks.

These developments emphasize the importance of beneficial ownership transparency, corporate governance and modernized risk management frameworks. As such, AFC professionals have additional expectations, as depicted in Table 2 below.

Source and visualization by: Natfluence, Jon Estreich, CAMS-Audit, CFE10

The responsibilities in Table 2 reflect a shift toward a highly integrated, technology-centric approach in the AFC domain, emphasizing the need for AFC professionals to continuously adapt to evolving regulatory landscapes and employ technology to enhance compliance effectiveness.

To align with regulatory messaging and prepare for forthcoming expectations, AFC professionals can increase their aptitude in the following areas:

  1. Global regulatory dynamics: International regulatory frameworks, including FATF guidelines, EU AML directives and the interplay between different jurisdictions’ requirements and how global standards interact with local regulations.
  2. Digital assets and blockchain technology: The regulatory landscape, compliance requirements and technological aspects of cryptocurrencies, DeFi and NFTs—including the intricacies of digital assets, VASPs and blockchain technology.
  3. AI-integrated compliance strategies: Applications of advanced analytics, machine learning and GenAI to improve AFC functions—such as transaction monitoring, suspicious activity detection, regulatory reporting and risk assessment.
  4. Cybersecurity and fraud prevention: Evolving fraud schemes perpetrated by organized crime groups and solo fraudsters; the interconnectedness of fraud, cybercrime and money laundering; and advanced strategies to proactively monitor and safeguard against fraud.
  5. Sanctions and trade compliance: The dynamic scope of sanctions regimes and export controls, screening technologies to identify indirect ownership and control, and evasion tactics—particularly in high-risk jurisdictions and virtual currency transactions.

Additional areas of focus include those listed below.

  • Information sharing models: Information sharing provisions, the dynamics of public-private partnerships and the role of cross-border collaboration in combating financial crimes—including international information exchange protocols and privacy considerations.
  • Beneficial ownership and transparency: Due diligence processes to analyze beneficial ownership and uncover hidden risks in corporate structures, including global beneficial ownership databases and cross-referencing techniques.
  • Regulatory technology (regtech) and financial technology (fintech) innovations: Technological advancements in regulatory and financial sectors, and their applications in financial crime prevention.
  • Data privacy and protection: Data protection laws and best practices for safeguarding sensitive financial information to prevent data breaches.
  • AI ethics and governance: Implications of AI applications in financial settings, AI bias mitigation, model explainability and regulatory expectations for AI use in compliance.

Final Thought

A rise of “AFC superhumans” signals more than a skills evolution—it is a reawakening of what is possible in financial crime prevention.

Neil Sternthal, CEO of ACAMS, thinks of it like this: “As an AFC community we are the first line of defense and must do more, faster…. We must consider that our community is expanding to include programmers, software engineers, data analysts and technologists. AFC practitioners are being exposed to new technologies. There is a need for AFC practitioners to better understand technology and for technologists to better understand AFC compliance.”11

Ultimately, the fight against financial crime is a test of our resolve to blend human insight with innovation.

If we can bring AFC leaders and institutions together to create a space where talent and vision meet, there is an opportunity to redefine the future.

The second article in this series, which will be published on ACAMSToday.org, will provide readers with a discussion of trending intangibles for leadership-level success and a roadmap for targeted skills acquisition.

Jonathan Estreich, CAMS-Audit, CFE, award-winning four times certified career strategist, founder, Natfluence (Career Growth Fuel), New York, NY, USA, jon@natfluence.com,

Additional contributor: Shaun Creegan, managing director, Protiviti, AML and Sanctions expert, New York, NY, USA, shaun.creegan@protiviti.com, 

The views expressed in this article by the author and contributing experts do not necessarily represent the views or opinions of their organizations.

  1. This includes customer due diligence/know your customer, transaction monitoring, suspicious activity reporting and investigations, Office of Foreign Assets Control sanctions, oversight and governance, operations and technology, anti-bribery and corruption and AML risk management.
  2. “Request for Information on Uses, Opportunities, and Risks of Artificial Intelligence in the Financial Services Sector,” U.S. Department of the Treasury, June 12, 2024, https://www.federalregister.gov/documents/2024/06/12/2024-12336/request-for-information-on-uses-opportunities-and-risks-of-artificial-intelligence-in-the-financial
  3. “The fight against money laundering: Machine learning is a game changer,” McKinsey & Company, October 7, 2022, https://www.mckinsey.com/capabilities/risk-and-resilience/our-insights/the-fight-against-money-laundering-machine-learning-is-a-game-changer; Rob Norris, “Applying AI to Fight Crime,” Nasdaq Verafin, June 6, 2024, https://verafin.com/2024/06/applying-ai-to-fight-crime/
  4. David Choi, Stefano Boezio and James Gordon, “Embracing AI In Anti-Financial Crime Compliance,” Oliver Wyman, February 2024, https://www.oliverwyman.com/our-expertise/insights/2024/feb/embracing-ai-in-anti-financial-crime-compliance.html
  5. “AML Career Guidance & Job Search Guides for AFC Professionals,” Natfluence, https://natfluence.com/aml-career-guidance/
  6. “Acting Comptroller Discusses Artificial Intelligence and Financial Stability,” OCC, June 6, 2024, https://www.occ.gov/news-issuances/news-releases/2024/nr-occ-2024-61.html
  7. This term refers to techniques that assign scores to input variables (features) based on their contribution to the predictive power of the model.
  8. “ACAMS Global AFC Threats Report 2024,” ACAMS, January 31, 2024, https://www.acamstoday.org/global-afc-threats-report-2024/
  9. “Florence Hui: Maximizing AFC Efficiency,” ACAMS Today, July 2, 2024, https://www.acamstoday.org/florence-hui-maximizing-afc-efficiency/
  10. “AML Career Guidance & Job Search Guides for AFC Professionals,” Natfluence, https://natfluence.com/aml-career-guidance/
  11. Karla Monterrosa-Yancey, ”Neil Sternthal: Innovation, Collaboration and the Future of AFC,” ACAMS Today September-November 2024, September 5, 2024, https://www.acamstoday.org/neil-sternthal-innovation-collaboration-and-the-future-of-afc/