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April 7, 2017

There are a multitude of ways to organize teams, workflows, and processes in any anti-money laundering (AML) program. As the complexity of risks and regulatory scrutiny increase, hiring, developing, and managing effective AML business functions is becoming progressively difficult. One recommendation for organizing AML teams is to create a Triage Team, which can serve the following functions:

  • Adjudicates and processes all escalations and exceptions from various AML functions (CDD, transaction monitoring, sanctions screening, etc.)
  • Captures, analyzes, and communicates risk trends across business and AML functions
  • Makes recommendations to apply limited resources (people, time, technology, data, and money) to high risk or severe impact risk pools (such as customer types or products)
  • Serves as a risk-focused AML resource for compliance training programs
  • Acts as a central pipeline for risk evaluation outputs (SARs, relationship memos, etc.)
  • Helps communicate AML program successes across all relevant business units

Structuring the Team

When structuring a triage team, it is important to fill its ranks with high performing employees from the various AML business units (monitoring, screening, onboarding, etc.) who can more quickly adjudicate risk exceptions and take appropriate action on unique activity and entities.

For example, a less experienced employee conducting transaction analysis may spend three or four times longer adjudicating a suspicious alert containing non-standard, unfamiliar characteristics than an experienced member of the triage team. Additionally, the standard review process conducted by quality control or team leaders may be slowed by focusing significant time and effort on an insignificant volume of cases.

Under this circumstance, the business unit experiences less efficient production and the unique risk factors contained in the alert may not be properly captured for trend collection and analysis. By utilizing a triage method of escalation, the AML business unit gains the ability to filter and escalate unfamiliar risk factors, process more alerts and cases, limit disruption to business as usual, and produce higher quality output through specialization.

It's About More than the Numbers

Organizationally, advancing team members from business units to triage teams, then back into leadership roles within the AML program can enable a natural developmental progression from specialized work with little experience, to higher impact work requiring broad AML skillsets and experience.

Triage models may also facilitate compensation structures that directly align to experience and capabilities, which can be challenging for organizations in a rapidly expanding and mobile AML talent environment. Other benefits include reduced knowledge silos, shared best practices across business units, and increased on the job training effectiveness via employees returning from triage teams. Additionally, improving workflow volumes and quality may allow AML program leadership to shift personnel to other risk areas within the organization.

The Triage Team Model

  • Providing clear, decisive triggers for AML units to escalate alerts and cases to triage teams
  • Focusing on specialization (training and development) for each AML function or unit
  • Providing opportunities for team members to move to different AML units over time and to bring their developed skills to the triage team
  • Assessing the resource application within the triage team on a consistent basis
  • Delivering consistent communications from triage teams to all relevant business units (risk trends, regulatory updates, and successes)
  • Maintaining strong working relationships and open lines of communication between the triage team, business units, auditors, and senior decision makers

Why it Makes Sense

Synchronizing your organization’s process improvements alongside talent development can enable more efficient, less costly compliance operations while reducing personnel attrition and promoting individual growth. Ultimately, an efficient, well-rounded compliance talent pool will help mitigate the enduring regulatory, operational, and reputational risks that AML programs seek to minimize.