There is a lot of conversation in the industry about the inefficiencies of “traditional” rules-based monitoring systems, Alert-to-SAR ratios, and the problem of high false positive rates. Let me add to that conversation by throwing out what could be some controversial observations and suggestions… Current Rules-Based Transaction Monitoring Systems – are they really that inefficient? […]
There are very few, if any, areas of the world, let alone our country, that aren’t watching an unprecedented situation unfold in front of our very own eyes. Confirmed cases of COVID-19, also known as the Novel Coronavirus, have been found in more than 80% of the world’s countries, and new cases show up […]
Machine Learning and Artificial Intelligence proponents are convinced – and spend a lot of time trying to convince others – that they will disrupt and revolutionize the current “broken” AML (anti-money laundering) regime. Among other targets within this broken regime is AML alert generation and disposition and reducing the false positive rate. The result, if […]
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 […]
What It Is The general “rule of thumb” in the AML world is that for every method that the financial industry initiates to detect and deter money laundering, the launderers devise a new way around it. We all play by the same rules and the governing authorities have gracefully published those rules so that they […]
On July 24, 2019, the OCC issued Bulletin 2019-37 Operational Risk: Fraud Risk Management Principles. In our first article in this series, we distilled the guidance down to its three component parts governance/culture, risk management, and reporting. In this article, we cover the two central components of a compliant fraud risk management program. These are […]
Part 1: Governance, Operations, Management Introduction On July 24, 2019, the OCC issued Bulletin 2019-37 Operational Risk: Fraud Risk Management Principles. The OCC guidance can be broken down into three components: Governance/Culture Ethical standards and employee accountability. Risk Management Operations Policies, procedures, processes, controls, personnel sufficient to identify, measure, monitor, and […]
Introduction In this article, I will present updated fundamentals on what is an Anti-Money Laundering (AML) model validation as defined by the Office of Comptroller of the Currency (OCC) guidance. In an effort to provide oversight on the model validation process, I will demonstrate the definition, it’s origin, how that translates to its use in […]
What is explainability? There is a lot of chatter about it in relation to software applications, in particular those that leverage emerging technologies such as artificial intelligence (AI) and machine learning (ML). Regulators have been sort of blunt about use of these technologies: a firm can’t just buy and implement a new piece of technology, […]
There can be a precarious path bankers walk assuming that a community bank has a low risk for money laundering. The reality is that nefarious actors know this, and while these banks are often doing their best with the staff and budget they have to work with, bank leaders and board members need to be […]
