We, the undersigned, hereby petition the Association of Certified Anti Money Laundering Specialists and its parent organization Becker Professional Education, a subsidiary of Adtalem Global Education, to reconsider the recently announced changes to the CAMS recertification policy, that will make it significantly cost prohibitive for many current and prospective members.

On 11/15/2019, a surprising announcement stated there would be significant changes to the certification/recertification policy for CAMS.  Although we commend the policy changes for certification, broadening eligible qualifying credits from education/work experience, we believe the changes to the recertification policy present some concerns for members.

Previously, recertification requirements allowed members to receive 24 credits from work experience, 12 credits from continued ACAMS membership and the remaining education credits from ACAMS provided offerings, whether paid or free – total of 60 credits.

  Under the new policy, the total credit requirement may have been reduced to 30 credits, but this can be discounted by the fact that previously 36 credits could be obtained through a combination of work experience and ACAMS membership. Furthermore, only 6 credits can be received for free ACAMS webinars, leaving members with no options besides receiving the remaining 24 credits through paid ACAMS/3rd party approved educational offerings.  The approximate cost for 2 credits is $250 giving a total minimum cost of $3000 to gain required educational credits for recertification every 3 years.

Our primary concerns are as follows:

1)     New recertification requirements are a significant departure from the previous policy, which potentially had little to no cost for recertification.  The changes make recertification significantly more cost prohibitive for current and prospective members.

2)     For those certified in 2018/19 (recertifying in 2021), it is very surprising that new requirements retroactively apply to them without any prior notice.  It’s reasonable to expect that a ‘Grandfather clause’ would apply to all certified members prior to the policy change.  Many members factored previous requirements into their decision to pursue CAMS certification.  For those that certified in early 2018, two years have passed, therefore it is not possible to plan ahead and spread the burden of cost/effort for recertification over the 3 years.

We strongly urge ACAMS to address the raised concerns through the following measures:

1)     Revise the recertification policy to reduce expense of recertification, particularly for independent professionals.  This may be achieved by reconsidering the announced changes to allow more free credits or by offering a new class of membership for independent professionals besides the current categories – private and government.

2)     Ensuring members that certified in 2018/19 (prior to policy change) are still able to recertify under the previous policy that was in place.  A ‘Grandfather clause’ should cover these individuals and policy changes should only apply to all future members, recertifying from 2023 onwards.  This way they are given enough prior notice to make a fair, informed decision.

Becker Professional Education is owned by Adtalem Global Education (formerly DeVry Education Group) which is a for-profit education business that has been embroiled in a number of past lawsuits and controversies surrounding its past conduct.  It has not escaped our attention that ACAMS was recently purchases by Becker Professional Education in 2016 for $330 million. 

According to the new policy FAQ page: “The primary reason for (the policy) change is to simplify our recertification requirements....focusing the credit requirements for recertification on the education component.”

Considering there is immaterial change to the total required education credits (from 24 to 30), it would appear that the primary motive for the policy change is likely driven by Adtalem/Becker’s desire to recoup their investment as soon as possible.  Unfortunately, this has come without reasonable concern for how this will impact the certified CAMS community.

ACAMS is the largest member-driven AML organization dedicated to enhancing the knowledge and expertise of financial crime professionals with over 60,000 members.  Members feel proud to be a part of an organization that offers professional recognition as well as valuable educational and networking opportunities in the field.

 There are many independent financial crime professionals (i.e. non-enterprise members) that cover their own certification/ recertification costs. Unfortunately, these changes will cause many current and prospective members to reconsider (re)certification in the future.  We encourage ACAMS to reconsider how this policy change will affect current and future members of the community.