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 […]
Every year we conduct surveys on important anti-money laundering (AML) topics. A recent survey focused on the topic of Marijuana Related Businesses (MRBs). While marijuana remains illegal on the federal level, more states have begun legalizing both adult and recreational marijuana on a state level. Although the political landscape has changed, with the Democrats controlling […]
There has been a problematic lack of merchant payment solutions and access to banking services for the cannabis industry in the United States since its inception. There are many prevalent misconceptions and myths about why this gap in banking services persists, despite the growing success of the cannabis industry in the United States. While it […]
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 […]
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 […]
If this year taught us anything, it is that we do not really know what is going to happen next. We heard about COVID-19 and then our entire way of life changed overnight. Some financial institutions were better prepared than others. For example, those who had employees working remotely when the pandemic hit, were positioned […]
Every quarter we conduct a survey on important topics to anti-money laundering (AML) professionals. A recent survey covered the topic of the use of BSA/Transaction Monitoring software. Although having an automated transaction monitoring software is not required for financial institutions, having a technology—whether it be a manual process through spreadsheets, or something through an automated […]
Introduction How do you know if the thresholds are set correctly in your OFAC (Office of Foreign Assets Control) Sanctions Filtering or BSA (Bank Secrecy Act) Transaction Monitoring system? That is certainly an important question, and a mystery in the world of anti-money laundering (AML). Commonly in the financial industry, and for the purposes of […]
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 […]
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 […]
