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 […]
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, […]
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 […]
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 […]
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 […]
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. […]
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 […]
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 […]
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 […]
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 […]
