As part of international efforts to prevent further development of Iran’s nuclear weapons program, on December 31 2011 the United States (US) imposed various ranges of diplomatic and legal sanctions to prevent foreign financial institutions (FFI’s) from conducting transactions with Iran through the US Department of the Treasury; Office of Foreign Assets Control (OFAC) regulations. […]
Human trafficking is in the news more and more. When it is mentioned, many have a picture in their minds of Asian women working in nail salons. However, this stereotyping of human trafficking is deadly as it blinds people to the trafficking that occurs in their own local community and the ill gotten monies that […]
In my over 35 years of providing recruitment and staffing services to the financial industry, I have been through the ups and downs of talent shortages, retention issues, and compensation variances. These are commonplace issues that occur in many departments due to economic reasons, budgets, training gaps, etc. However, it seems that these challenges are […]
There is so much pressure these days to get it done right the first time… even though no BSA/AML solution or program is 100% perfect. And if look-backs (recommended or mandated) are not completed successfully, you will find yourself in a never ending pitfall of data quality issues, growing BSA/AML requirements, changing face of risk and compliance priorities, […]
Introduction Independent verification and validation, IVV, model validation, validation or; as Shakespeare might say, a validation by any other name is still a validation. Regardless of the name it has evolved and been redefined over time. This article will cover the origin, OCC guidance, regulatory pressure, IVV methodology, reporting, independence, and vendor due diligence in […]
For foreign branches conducting business in the U.S., head office can sometimes be both Dr. Jekyll and Mr. Hyde. On occasion this has proved to be a problem. At times banks are faced with a bureaucracy of business, which can get in the way, and sometimes they can be pressured to make decisions with the […]
In order to stay compliant with today’s financial standards, most banks utilize some type of anti-money laundering (AML) program, which includes software. These programs follow BSA, OFAC, CDD/KYC, and FinCEN 314(a) guidelines to make sure banks are following AML compliance laws on a daily basis. It’s necessary to review the software and governance program involved […]
It’s legal, it’s not legal. To quote comedian George Carlin, “well, which one is it, have it make up its mind and come on back.” As bankers, compliance professionals and advisors, we don’t have the luxury of waiting for business opportunities, financial gains and other such pivotal moments to pass us by; and with an […]
Inherently, as a financial institution doing business every day, you capture sensitive data about your customers. That sensitive data includes customer, account, and transaction data, and is housed in your Anti-Money Laundering (AML) system, if not other places as well. Your accounting system is likely well protected from insider fraud and internet attacks, but your AML […]
Introduction On March, 3, 2015, the New York Regional Director for the FDIC, John Conneely, conducted a regulatory teleconference along with Special Activities Case Managers Kristi Keating and Rebecca Williams, which focused on BSA hot topics, trends and tips to maintain Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance. This article is intended to educate board members, […]
