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 […]
Here you will find the AML-ology curriculum, our monthly curated articles, to help any BSA professional stay up-to-date on the latest trends and learn answers to timeless challenges. We share articles written by a number of industry sources that we believe take an academic approach to the challenges anti- money laundering (AML) professionals face, and actual solutions for you to implement. These articles are published monthly and sent directly to you when you sign up to be an AML-ology Scholar!
A Helpful Guide to the Examination Process, Part 2
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, […]
A Helpful Guide to the Examination Process, Part 1
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 […]
Regulation 504 and The Evolving Compliance Landscape
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 […]
The Science Behind False Positive Tuning
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 this […]
Who Owns the Money? – Part Two
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, ‘Who Owns the Money?’. I can hear it already, what now? Who changed it, why, etc, etc, etc. […]
A Refreshing Look at CDD
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 […]
BSA Update from the Regulators
On a recent conference call, a number of regulatory bodies were represented, primarily from the northeastern area of the United States; such as the Federal Reserve of Philadelphia, Federal Reserve of New York, New Jersey Department of Banking, FDIC and the OCC. During the call, they agreed that the Bank Secrecy Act (BSA) continued to […]
A Top Down Understanding of Transaction Monitoring Software – Part Two
As an AML (anti-money laundering) professional it is often hard to fully understand AML transaction monitoring software, including the terms, functionality, data dependencies, and limitations. These challenges can make it difficult in creating and maintaining an effective AML governance program. Often we see when AML governance programs are built upon their AML software, they have […]
A Top Down Understanding of Transaction Monitoring Software – Part One
As an AML (anti-money laundering) professional it is often hard to fully understand AML transaction monitoring software, including the terms, functionality, data dependencies, and limitations. These challenges can make it difficult in creating and maintaining an effective AML governance program. Often we see when AML governance programs are built upon their AML software, they have […]