Imagine this: Nancy at ABC Credit Union calls Rayleen at MainStreet Bank to inquire about 3 large ACH transactions moving between accounts of the two financial institutions (FIs). The three transactions appeared in the transaction monitoring system at ABC Credit Union, prompting an AML investigation. Nancy suspects their member is a money mule. Rayleen at […]
Warren Buffett once said, “When people tell me they’ve learned from experience, I tell them the trick is to learn from other people’s experience.” This is true in many areas of life, especially when it comes to BSA Consent Orders. BSA (Bank Secrecy Act) and OFAC (Office of Foreign Assets Control) personnel are wise to […]
Human traffickers are quick to adapt their business models based on technology trends to grow their markets and increase their profits. Traffickers use technology as a force multiplier to profile, recruit, control and exploit their victims via a variety of online platforms, where personal information and details of people’s locations are readily available, they connect […]
When the Soviet Union collapsed, I was a member of the Panamanian underworld that laundered drug money for Colombia’s Cali drug cartel. My friends in Panama’s mafia, several of whom had high-level KGB connections, also worked with Russian power brokers to launder and invest in assets stolen from the Russian public as its economy was […]
Ransomware has become one of the most dreaded problems in the cyber world and it’s only getting worse. Much worse! Traditionally, ransomware was a trojan horse malware program which when it found a new host computer simply went off, encrypted all the data it could find, and sent the user an onscreen message to pay a […]
Human Trafficking Definitions U.S. law defines human trafficking (also known as trafficking in persons, trafficking in human beings, or modern slavery) as the use of force, fraud, or coercion to compel a person into commercial sex acts or labor / services against their will. The Action-Means-Purpose (AMP) model describes the federal definition of human trafficking […]
Background In Q4 2021, the value of all crypto-assets in circulation stood close to $3Tn. At the start of 2021, that number stood at $1Tn, and nearly a decade ago did not exist. The rapid rise of interest in crypto has stunned many skeptics. The increase of crypto-assets and associated wallets has been accompanied by […]
Introduction As outlined in Section 352 of the USA PATRIOT Act, which stands for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001.”, an Anti-Money Laundering (AML) Program shall establish “an ongoing employee training program…”.[1] Collectively speaking, regulatory bodies have not explicitly defined what this […]
When FinCEN issued their AML/CFT (Anti-Money Laundering/Combating the Financing of Terrorism) Priorities on June 30, 2021 1, one of those priorities was proliferation financing. But what exactly is “Proliferation Financing” and how should financial institutions manage this risk? FinCEN did not really give much insight into any of the priorities or indicate what they expect […]
To begin, let’s define our topic. Financial Elder Abuse is “when someone takes or misuses another person’s money or property for the benefit of someone other than that person. For example, neighbors, caregivers, professionals, and even family or friends may take money without permission, fail to repay money they owe, charge too much for services, or not do […]
