Rick Small : A storied career in AFC
Rick Small leads the Financial Crimes team for Truist , which includes managing anti-money laundering ( AML ) compliance , controls and investigations , fraud management , internal and external investigations and physical security . He joined Truist in 2016 as the first Financial Crimes program director .
With over 35 years of experience in the public and private sectors , Small was the senior advisor for Anti- Money Laundering and Financial Crimes with Ernst & Young ; the senior vice president , Enterprise- Wide Anti-Money Laundering , Anti-Corruption and International Regulatory Compliance for American Express ; and the global AML leader for GE Money , a division of General Electric . Small began his private sector career as managing director , Global Anti-Money Laundering for Citigroup .
Prior to these private sector roles , he held several positions with the U . S . government , first as a federal prosecutor with the U . S . Department of Justice in the Antitrust Division and then with the Organized Crime Strike Force , followed by his role as senior counsel for law enforcement at the U . S . Department of the Treasury . His most recent government position was on the staff of the Board of Governors of the Federal Reserve System as deputy associate director in the Division of Banking Supervision and Regulation . Small is a member of the Advisory Board of ACAMS and a past chairman of the board .
ACAMS Today ( AT ): With over 35 years of experience in the antifinancial crime ( AFC ) industry , what do you consider your biggest professional accomplishment ?
Rick Small ( RS ): I would be remiss if I didn ’ t say that the biggest accomplishment for me was , and continues to be , meeting all of the fantastic , like-minded folks who are dedicated to the fight against money laundering and view this as a mission and a calling rather than a job .
As to specific accomplishments , the prosecution of Bank of Credit and Commerce International ( BCCI ), for those who remember , was a significant victory for the government and for me personally . The development of several regulations , including suspicious activity reporting and co-authoring the first Bank Secrecy Act ( BSA ) examination manual , were also significant milestones for me .
AT : Having served in the public and private sectors , what would you say is the biggest challenge in implementing effective publicprivate partnerships to deter financial crime ?
RS : In the immediate days after 9 / 11 , when I had just left the government for the private sector , I reached out to my now very good friend Dennis Lormel , who , at the time , was a senior official in the Federal Bureau of Investigation . We were able to quickly coalesce a group from both the public and private sectors to work very closely over a number of months with the common goal of protecting the U . S . from further attacks and tracking down perpetrators . I use this as an example of the public-private partnership working at its best . While partnerships continue today , given all of the priorities , it is sometimes difficult to identify , focus on and commit resources to the most important priority , which can negatively impact some partnerships .
AT : In your opinion , which regulation has been the most valuable to the AFC industry ?
RS : Suspicious activity reporting , in my opinion , is the most valuable regulation . At its core , the idea that financial institutions can report suspected illicit activity to the government without recourse to provide the government with the leads it needs to investigate and hopefully prosecute those who are using the financial sector to commit crimes is a fundamental tenant of risk management . Of course , like all regulations , over time , there should be a reevaluation and reassessment as to whether the regulation is still working as intended or if an update or overhaul is required .
ACAMS Today | December 2023 – February 2024 51