The word “Tuning” may bring to mind the idea of tuning an instrument. As we all know, if your instrument is not tuned properly, no one will appreciate all the time and effort the musician puts into playing it. If all the instruments in an orchestra are not tuned to the chosen frequency, for example, […]
The word “Tuning” may bring to mind the idea of tuning an instrument. As we all know, if your instrument is not tuned properly, no one will appreciate all the time and effort the musician puts into playing it. If all the instruments in an orchestra are not tuned to the chosen frequency, for example, […]
Whether we like it or not, regulatory examinations are a fact of life for all banks and bankers. Accommodating examinations from the regulators including the associated costs is something that has been dealt with for decades – some might say ad nauseum! Nonetheless, we are stuck with it! It is going to be around for […]
A global problem. What can we do as US financial institutions to help bring it to an end? Last month we discussed the global blight of human trafficking under its various names. It is second only to global drug trade in terms of its profitability for the criminals who traffic in persons. It produces well […]
Consider the following: On October 23, 2019, the bodies of 39 Vietnamese people—29 men, 2 boys, and 8 women — including 10 teenagers; the youngest were two 15-year-old boys—were found in the trailer of a refrigerated trailer in Essex, United Kingdom. The trailer had been shipped from Belgium, to UK. Although it was a refrigerated […]
What is snow washing? Hint: it has nothing to do with the Ivory Snow Detergent washing powder. Wikipedia tells us that Snow washing refers to hiding illegitimate financial transactions often for purposes of tax evasion in Canada. The term being an amalgam of the words snow meaning purity as well as the cold Canadian climate and washing referring to money […]
Last month we discussed the pre-examination period and the actual on-site examination from the perspective of both bankers and examiners. One of the key themes that emerged was the need for clear and open communications between all parties. This time, we’ll continue with a discussion of the post-examination process, some comments about Supervisory Enforcement Actions, […]
I think we would all agree that the examination process has evolved over the years. With the greater technology, sophistication, and complexity of our banks, what used to be an annual surprise examination has taken on more of a continuous process. Granted, there are still periods of more intense activity such as actual on-site work, but […]
This is the first of some articles that I will write on various BSA AML related subjects. I must warn the reader that the views expressed are my own and represent neither the views of ARC Risk and Compliance nor my former employer, the Federal Reserve Bank of New York. By way of background, my […]
