In 2004 the FFIEC quietly and subtly shifted the BSA examination paradigm with the publication of the Bank Secrecy Act / Anti-Money Laundering Examination Manual (“the Manual”). The Manual introduced to examiners the concept of determining an institution’s money laundering, terrorist financing, and OFAC risks through a matrix of pertinent topics rated as Low, Medium, […]
Introduction The heart and soul of your program is your BSA (Bank Secret Act)/AML This article will define what an AML model validation is and it’s importance. We will also delve into our top ten findings of AML model validations and ways to avoid them. What is an AML Model Validation? An […]
A Brief Summary Oddly, despite its significance in the BSA/AML/CFT/OFAC Compliance universe, the BSA Risk Assessment has no statutory requirement even though it is the foundation of any Compliance Program. As compliance professionals, we construct our transaction monitoring systems, OFAC filtering programs, and our whole Compliance Programs, on the risks that we have determined based […]
Shortly after the 4th AML Directive took final effect and prior to the 5th AML Directive final compliance date (3 January 2020), the European Parliament passed Directive 2018/1673 – the 6th AML Directive. AMLD6 has a compliance date of 3 December 2020. The Directive increased the number of predicate offense categories to twenty-two. The newly […]
There are very few, if any, areas of the world, let alone our country, that aren’t watching an unprecedented situation unfold in front of our very own eyes. Confirmed cases of COVID-19, also known as the Novel Coronavirus, have been found in more than 80% of the world’s countries, and new cases show up […]
What It Is The general “rule of thumb” in the AML world is that for every method that the financial industry initiates to detect and deter money laundering, the launderers devise a new way around it. We all play by the same rules and the governing authorities have gracefully published those rules so that they […]
On June 30, 2016, the New York State Department of Financial Services (“NYS DFS”) issued the final version Rule 504, “Banking Division Transaction Monitoring and Filtering Program Requirements and Certifications.” The Rule takes effect on January 1, 2017, with the first reporting date of April 15, 2018. In a sense, the Rule follows upon the […]
A Brief Summary Oddly, despite its significance in the BSA/AML/CFT/OFAC Compliance universe, the BSA Risk Assessment has no statutory requirement even though it is the foundation of any Compliance Program. As compliance professionals, we construct our transaction monitoring systems, OFAC filtering programs, and our whole Compliance Programs, on the risks that we have determined based […]
Overview Many Financial Institutions have installed market-tested BSA/AML Transaction Monitoring Systems to fulfill the requirement to seek out and report on patterns of suspected money laundering and terrorist financing. At the heart of the monitoring activity lies the process of clearing alerts and cases that the monitoring software flags as suspicious, based on the parameters […]
On June 30, 2016, the New York State Department of Financial Services (“NYS DFS”) issued the final version Rule 504, “Banking Division Transaction Monitoring and Filtering Program Requirements and Certifications.” The Rule takes effect on January 1, 2017, with the first reporting date of April 15, 2018. In a sense, the Rule follows upon the […]
