One way or another weâve all done it. Completed the documentation, prepped the files, sent it for review and approval, and watched as the SAR we took time to support and document be dropped into that massive industrial cavern known as the governmental database. Rarely have we, or most of the analysts and advisers weâve […]
Its that time again, to revisit and amend our BSA policies, procedures, risk models and training. It seems it never ends, and it is for this very reason we are going to revisit our February 2015 article, âWho Owns the Money?â. I can hear it already, what now? Who changed it, why, etc, etc, etc. […]
Itâs legal, itâs not legal. To quote comedian George Carlin, âwell, which one is it, have it make up its mind and come on back.â As bankers, compliance professionals and advisors, we donât have the luxury of waiting for business opportunities, financial gains and other such pivotal moments to pass us by; and with an […]
Who owns the money? Thatâs a legitimate question to ask, but as the operator of a financial services company is the question accurate? In legal terms there can be numerous owners of any asset and it is generally broken down into two parts. The equitable owner and the legal owner. For many of us that deal […]
