In late February, the Superintendent of the New York State Department of Financial Services (the “DFS”) gave a speech at Columbia Law School on the role of state banking departments in the regulation of financial institutions. New York State has been the capital of the banking industry in the United States since before any of […]
Beyond the regulatory requirements (Federal Financial Institutions Examination Council, 2010), testing is conducting in different departments for different purposes. In the IT department you are focusing on software and system quality, bug identification and integration accuracy. The audit and compliance departments are validating the continued accuracy and compliance to policies and procedures. It is 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 […]
Who owns the money? That’s a legitimate question to ask, but as the operator of a financial services company is the question accurate? In legal terms there can be numerous owners of any asset and it is generally broken down into two parts. The equitable owner and the legal owner. For many of us that deal […]
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 an […]
In part one of this article, Implementation of AML Software: “The Keys to Success” Part 1 of 2, we discussed evaluating your needs, vendors, budget and having a good well thought-out plan, including a Business Requirement Document (BRD) and Functional Design Document (FDD). We covered some, not all, iterations that can change your needs or focus, […]
It’s often hard to judge just how much effort you will need to put forth on behalf of your institution in order to have peace of mind for AML compliance. On one hand you could put a great deal of effort into AML compliance, which could simply be a waste of money. On the other […]
Compliance monitoring is the continued self-assessment and adherence to policies, procedures, and processes within the compliance program. Due to increased regulatory scrutiny this role is expanding throughout the financial institution industry. Specifically, compliance monitoring is a designated role to review, sample, and identify control issues within a compliance program. The value of the role is […]
Compliance organizations face challenges on multiple fronts in their efforts to control anti-money laundering (AML) risk. The perpetrators of financial crimes continually seek new ways to circumvent the protections in place, putting the financial institution at reputational and financial risk. The regulators bring their broad exposure to the latest nefarious techniques to each examination in […]
