Sanctions are intended to exert economic pressure on targeted groups of persons and countries to either prevent conducting business as usual or, at the very least, make it more expensive to do so. It is hoped that such impediments will cause sanctioned parties to reconsider their course of action and change it. When the scope […]
There is a lot of conversation in the industry about the inefficiencies of âtraditionalâ rules-based monitoring systems, Alert-to-SAR ratios, and the problem of high false positive rates. Let me add to that conversation by throwing out what could be some controversial observations and suggestions⌠Current Rules-Based Transaction Monitoring Systems â are they really that inefficient? […]
There are very few, if any, areas of the world, let alone our country, that arenât 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 worldâs countries, and new cases show up […]
Machine Learning and Artificial Intelligence proponents are convinced â and spend a lot of time trying to convince others â that they will disrupt and revolutionize the current âbrokenâ AML (anti-money laundering) regime. Among other targets within this broken regime is AML alert generation and disposition and reducing the false positive rate. The result, if […]
Introduction In this article, I will present updated fundamentals on what is an Anti-Money Laundering (AML) model validation as defined by the Office of Comptroller of the Currency (OCC) guidance. In an effort to provide oversight on the model validation process, I will demonstrate the definition, itâs origin, how that translates to its use in […]
What is explainability? There is a lot of chatter about it in relation to software applications, in particular those that leverage emerging technologies such as artificial intelligence (AI) and machine learning (ML). Regulators have been sort of blunt about use of these technologies: a firm canât just buy and implement a new piece of technology, […]
BSA risks continue to evolve and time does not stand still for money launderers or fraudsters.  The criminals are always looking for non-traditional ways to accomplish the same results and financial institutions and BSA Officers often only rely on controls we are most comfortable with. This tendency is the starting foundation for BSA criticism.  Is your BSA program and […]
