Over the past decade, following the enactment of the Third European Anti-Money Laundering Directive (and the legislative decree implementing the Fourth Directive in Italy recently came into force), active collaboration to prevent the use of the financial system for money laundering and terrorist financing has become increasingly challenging, so much so that banks have had to adopt ad hoc internal regulations, procedures, and organizational structures. The specific nature of the matter has also required the acquisition of human resources with specific skills. skill professional.

From the perspective of a young person aiming to build their professional skills in line with market demands, this could represent an attractive prospect for employment in the credit sector. However, the economic crisis has forced credit institutions to regain profitability by cutting operating costs, including personnel costs.

We therefore asked ourselves to what extent the job market in the banking sector today offers practicable and attractive prospects and whether, in this context, the implementation of the anti-money laundering function could represent a chance longer.

We asked these questions to Dr. Giorgio Salvo, former Director of the Bari and Trento branches of the Bank of Italy, who now deals with anti-money laundering controls in banks, collaborating, among other things, on training activities organized by the ESB.

How has the banking job market evolved, and what are the employment prospects for those involved in auditing?
I belong to a generation that entered the job market in the 1970s, for which a "job in a bank" was still highly sought after, as it guaranteed job stability and, above all, significantly higher wages than other categories of employed workers. Over time, these advantages have gradually eroded, and today working in a bank seems to have lost much of its appeal.
However, if we compare the various sectors of the workforce, we can observe (ISTAT data) that real hourly earnings for employees in the credit and insurance sector, despite a temporary slowdown due to the crisis, remain significantly higher than the average for other sectors. Bank of Italy data also shows that, for Italian banks, unit labor costs have returned to pre-crisis levels.
What has really changed is the number of employed people, which has significantly decreased. The introduction of significant technological and organizational innovations (for example, the reduction in the number of branches and the spread ofhome banking), has in fact changed the mix of production factors within the banking industry. The complexity of banking activity has also increased further as a result of regulatory systems that, especially after the crisis, have imposed a qualitative leap in corporate planning and control functions.
Therefore, in the context of an overall reduction in the number of employees, the less qualified and lower value-added roles (for example, counter staff) have been reduced, in the face of a greater demand for professional figures oriented towards business areas, management functions and control functions.
It is likely that these trends will continue into the future: the changes we are witnessing can be considered structural in nature and therefore destined to last over time. Furthermore, the diffusion of digital technologies in the use of banking services in our country lags behind the European average: it is therefore reasonable to assume that the aforementioned process of organizational rationalization will last longer in our country than elsewhere.

What is the role of anti-money laundering in the internal control system?
The internal control system consists of a set of rules, procedures, and organizational structures that aim to achieve a variety of objectives: ensuring compliance with corporate strategies, achieving the effectiveness and efficiency of corporate processes, and, consequently, safeguarding the value of banking activities.
This set of functions falls under the responsibility of the strategic supervisory and corporate control bodies (typically the board of directors and the board of statutory auditors), which make use of the bank's organizational structures which report to the internal auditing function and the so-called "second level" functions, which include - in addition to the risk management and the compliance and confidentiality – including the anti-money laundering function, which is responsible for verifying that company procedures are consistent with the objective of preventing and combating violations of anti-money laundering regulations. The function is also responsible for identifying applicable regulations and their impact on internal procedures, as well as proposing organizational measures deemed necessary to address any operational deficiencies identified.
The anti-money laundering function, in accordance with regulatory requirements, has a special status that ensures its full and effective independence within the corporate organization. To this end, it is expected to report directly to the board of directors, be independent from operational functions, have access to all relevant corporate information, and be provided with adequate qualitative and quantitative resources.

How does the anti-money laundering function change following the implementation of the Fourth European Directive?
The functioning of the anti-money laundering function is governed by the Bank of Italy's Provision on the Organization, Procedures, and Controls of Banks in the Area of ​​Anti-Money Laundering of March 11, 2011. This is a secondary regulation issued pursuant to Legislative Decree 231 of 2007, which in turn implemented the Third European Directive. The Fourth Directive was transposed into Italian law by Legislative Decree no. 90 of May 25, 2017, which entered into force recently (July 4). It is therefore believed that to understand how the anti-money laundering function will change under the new European directive, we will have to wait for the new implementing provision to be issued by the Bank of Italy.