Anti-Money Laundering Lookbacks – Top 10 Staffing Lessons for Your Projects

Posted by Matt Walden on 08 16, 2022


An anti-money laundering (AML) lookback can be a serious headache for financial institutions. They're time consuming, expensive, and tedious, to say the least. But when a regulator requires your company to conduct one, it's essential to be as thorough as possible while creating efficient and quality work. 

The key to a successful anti-money laundering lookback is understanding the project's specific requirements and using the right people for the job. 

What Is an Anti-Money Laundering Lookback?  

An AML lookback is a review of suspicious activities (such as market manipulation or securities fraud) to determine if non-compliance has occurred. A regulator or compliance officer can order the lookback, or it might be part of your company's own internal controls, usually triggered by suspicious activity. 

The goal of an AML lookback is to identify suspicious activities and actions that may have caused non-compliance in the first place. The reason for this is twofold. First, the more non-compliance identified, the easier it is to determine what caused it. Second, if your internal controls are inadequate, you can then make any necessary changes. 

Either way, when an anti-money laundering lookback is required, it takes a lot of resources and time to review all transactions for your company. At Infinity Consulting Solutions, we know that this is a challenging situation to be in, but you don't have to go through this alone. 

10 Lessons We've Learned as an AML Staffing Agency  

At Infinity Consulting Solutions, we have vast experience staffing for AML projects quickly and are there to help our clients from start to finish. Over the years of assisting financial institutions with lookbacks, we've learned plenty on how to appropriately locate the talent you need to get this lengthy project done as efficiently as possible. 

1) Don't Just Hire Any Old Staffing Agency  

Lookbacks require many anti-money laundering professionals to audit all company transactions for suspicious activity, meaning you'll need a lot of talent for only a short period of time. This often leads financial institutions to look externally for AML contractors, which can lead to many risks if background checks and interviews aren't thoroughly conducted. 

Financial institutions must do their due diligence when partnering with a staffing agency. Before signing on, make sure to: 

  • Ask for references. 
  • Pick a firm that has experience in staffing for AML lookbacks. 
  • Find out if they onboard, train, and perform background checks themselves. 
  • Only say yes if the firm knows their contractor's performance history over the past year. 

The biggest mistake you can make is picking the wrong partner, so be sure to only work with specialized AML staffing agencies. 

2) Determine Your Current Staffing Situation  

Before hiring any anti-money laundering talent, meet with your team to see if there's anyone internally qualified and available to manage the lookback. If not, you may also need to consider hiring a project manager to oversee the lookback. 

3) Understand What You Need  

How long will your anti-money laundering lookback assignments last? What skills and expertise are necessary for this process? How many contractors will you need to get the job done on time? 

Asking yourself these questions sound simple but will save you a lot of time and hassle getting the project up and running. 

4) Determine an Ultimate Goal  

When preparing for a lookback (or any project), it's helpful to take the time to define goals, timelines, and responsibilities. Creating a strategic outline for your AML lookback will help you track progress and make it easier to finish the project on time. 

5) Rely on Your Staffing Partner  

Before you begin your search for anti-money laundering talent, connect with your staffing partner. They will have key insight into the AML job market and help you better align your positioning with market demand.  

6) Know That Demand for AML Talent Is at an All-Time High 

There's a high demand for AML talent in today's job market. And while companies are desperately seeking out this talent, there's only a small pool of knowledgeable experts in this field to choose from.  

For many financial institutions, lookbacks are required by regulators and can't be pushed back. Since there's a demand for AML contractors, work with your staffing firm to negotiate the best wages and ensure you get everything you need from your new hires.  

7) Start Finding Talent Early  

The sooner you start your search, the better. As your project needs to get up and running ASAP, you must be prepared to hire quickly while being thorough in your hiring process. By getting a jump-start, you have a better chance of reducing your labor costs, maximizing productivity, and eliminating skill gaps since you have more time to find the right talent for the project. 

8) Expedite the Hiring Process  

When searching for talent, it's crucial to do so quickly. You're not looking to fill the role of CFO; you're looking to find as many financial crime analysts, investigators, and subject matter experts as possible to ensure this lookback gets done correctly and quickly.  

These are not full-time positions, so don't treat them as such - most of the talent you're bringing on will only be on contract for only 9-12 months. They're brought on for a limited duration and a specific skill set to perform highly repetitive, detailed oriented work. So, you need to have a streamlined hiring process - if people look qualified on paper, try to keep the interview process short to determine if they are the right fit for this specific need. These contractors are likely to have multiple offers, so if they're qualified - act fast! 

9) Focus on the Candidate Experience  

You need a lot of talent quickly, and today's job seekers expect a lot out of potential employers. So, ensure you have a positive candidate experience! To achieve this: 

  • Simplify your application process 
  • Provide prompt and consistent communication  
  • Don't have too many interviews - keep it to 2-3 maximum 
  • Answer any questions your candidates ask 

10) Conduct Training & Continual Monitoring  

If you're working with a staffing firm to place dozens of anti-money laundering professionals, they will need onboarding and monitoring to ensure quality of work and that progress is being made. Many staffing firms will take on the responsibility of onboarding, training, and conducting production and quality scoring of a contractor's performance. 

Call on the Experts When You're Sanctioned for an AML Lookback  

However you choose to conduct your AML lookback, you need a partner that understands the market and industry best practices. Your partner should be your go-to for identifying, recruiting, and onboarding AML talent. ICS has experience providing AML talent quickly to leading financial institutions and will work with you to provide a seamless experience - from start to finish. If you need a lot of anti-money laundering contractors or want more information about our team, contact us today

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