Whether we like it or not, regulatory examinations are a fact of life for all banks and bankers. Accommodating examinations from the regulators including the associated costs is something that has been dealt with for decades – some might say ad nauseum! Nonetheless, we are stuck with it! It is going to be around for […]
A core tenet of economic sanctions is that they are more effective when they are imposed multilaterally, as that presents fewer alternatives for the targeted parties to continue their sanctioned activities. The past year, however, has shown few, if any, attempts at coordinated action. In fact, if anything, 2020 was more of a year in […]
A global problem. What can we do as US financial institutions to help bring it to an end? Last month we discussed the global blight of human trafficking under its various names. It is second only to global drug trade in terms of its profitability for the criminals who traffic in persons. It produces well […]
Consider the following: On October 23, 2019, the bodies of 39 Vietnamese people—29 men, 2 boys, and 8 women — including 10 teenagers; the youngest were two 15-year-old boys—were found in the trailer of a refrigerated trailer in Essex, United Kingdom. The trailer had been shipped from Belgium, to UK. Although it was a refrigerated […]
If this year taught us anything, it is that we do not really know what is going to happen next. We heard about COVID-19 and then our entire way of life changed overnight. Some financial institutions were better prepared than others. For example, those who had employees working remotely when the pandemic hit, were positioned […]
Every quarter we conduct a survey on important topics to anti-money laundering (AML) professionals. A recent survey covered the topic of the use of BSA/Transaction Monitoring software. Although having an automated transaction monitoring software is not required for financial institutions, having a technology—whether it be a manual process through spreadsheets, or something through an automated […]
Introduction 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 […]
Shortly after the 4th AML Directive took final effect and prior to the 5th AML Directive final compliance date (3 January 2020), the European Parliament passed Directive 2018/1673 – the 6th AML Directive. AMLD6 has a compliance date of 3 December 2020. The Directive increased the number of predicate offense categories to twenty-two. The newly […]
What is snow washing? Hint: it has nothing to do with the Ivory Snow Detergent washing powder. Wikipedia tells us that Snow washing refers to hiding illegitimate financial transactions often for purposes of tax evasion in Canada. The term being an amalgam of the words snow meaning purity as well as the cold Canadian climate and washing referring to money […]
Sanctions are intended to exert economic pressure on targeted groups of persons and countries to either prevent conducting business as usual or, at the very least, make it more expensive to do so. It is hoped that such impediments will cause sanctioned parties to reconsider their course of action and change it. When the scope […]
