If a willingness to do the right thing were the fuel that powered the attack on money launderers, that initiative would be a total success. Compliance professionals, regulators and law enforcement officers are motivated, but we struggle to think outside the box and change our method of operation. It’s time for us to work together […]
This article was first published in the NJ Bankers Magazine. For years now, financial institutions have had to focus on the prevention of money laundering. Then in 2001, after the attack on 9/11 and the passage of the USA PATRIOT ACT (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism) […]
Structuring. That old thing? Yeah, that. Some may have stopped at the title. But if you are a community bank or credit union – you are plagued day-to-day with structuring activity and alerts. Cash is still king in smaller institutions. The chances of your analysts viewing this incorrectly – and dispositioning alerts incorrectly – is […]
Introduction The heart and soul of your program is your BSA (Bank Secret Act)/AML This article will define what an AML model validation is and it’s importance. We will also delve into our top ten findings of AML model validations and ways to avoid them. What is an AML Model Validation? An […]
As with any payment network, the ACH Network sees its share of fraudulent transactions. Fraudsters have set their sights on complex schemes that utilize Account-to-Account (A2A) transfers to funnel laundered money. Scenario One: The Mule Convinced she is in love with someone she met through an online dating website, Jane agrees to accept deposits […]
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 may […]
Every year we conduct surveys on important anti-money laundering (AML) topics. A recent survey focused on the topic of Marijuana Related Businesses (MRBs). While marijuana remains illegal on the federal level, more states have begun legalizing both adult and recreational marijuana on a state level. Although the political landscape has changed, with the Democrats controlling […]
A Brief Summary Oddly, despite its significance in the BSA/AML/CFT/OFAC Compliance universe, the BSA Risk Assessment has no statutory requirement even though it is the foundation of any Compliance Program. As compliance professionals, we construct our transaction monitoring systems, OFAC filtering programs, and our whole Compliance Programs, on the risks that we have determined based […]
This is one of those questions that keep OFAC Officers up at night. Due to the complexity of the OFAC sanctions and the scope of application, it is a challenge to create a robust program and think of everything. However, with the potential of fines with even one violation, and the size of fines being issued for multiple violations, it is imperative that financial institutions have a strong OFAC program. A strong program must […]
There has been a problematic lack of merchant payment solutions and access to banking services for the cannabis industry in the United States since its inception. There are many prevalent misconceptions and myths about why this gap in banking services persists, despite the growing success of the cannabis industry in the United States. While it […]
