BSA risks continue to evolve and time does not stand still for money launderers or fraudsters. The criminals are always looking for non-traditional ways to accomplish the same results and financial institutions and BSA Officers often only rely on controls we are most comfortable with. This tendency is the starting foundation for BSA criticism. Is your BSA program and […]
Structuring – You’re Probably Not Getting It Right 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 […]
Introduction In my twenty years of being a BSA officer, I’ve learned a lot, both through any successes my team has had, and through the mistakes I’ve made. In this article, I’m going to share with you all the things that have stood out to me in my career: all the AML stakeholders, the full […]
Let’s put these numbers in perspective. 99% of laundered money is not caught. 90% of the resources spent catching suspicious actors are wasted. 100 % of US banks have known this for years. How did we get here? Modern technology, specifically data analytics, is well-suited to address this problem. Why hasn’t this problem been solved? […]
One way or another we’ve all done it. Completed the documentation, prepped the files, sent it for review and approval, and watched as the SAR we took time to support and document be dropped into that massive industrial cavern known as the governmental database. Rarely have we, or most of the analysts and advisers we’ve […]
How do these Guidance items apply to a virtual currency business located in a foreign country? On July 21, 2011, FinCEN published in the Federal Register a final rule on definitions and other regulations relating to money services businesses.[1] An entity may now qualify as a MSB under the Bank Secrecy Act regulations based on […]
Introduction Billions of dollars in fines have been paid by the banking industry for “inadequate” AML programs even though our biggest banks devote huge sums and thousands of people in their efforts to comply. The emerging virtual currency business is just getting its “toes wet” in the serious and high-stakes business of AML compliance. To make […]
There is so much pressure these days to get it done right the first time… even though no BSA/AML solution or program is 100% perfect. If look-backs (recommended or mandated) are not completed successfully, you will find yourself in a never ending pitfall of data quality issues, growing BSA/AML requirements, changing face of risk and […]
As the term connotes, most people would probably think that money laundering is the process of making illicit funds appear legitimate or, more simply put, clean dirty money. In the quintessential money laundering-themed TV show, Breaking Bad, a car wash business was used to clean dirty money earned by the main character, Walter White, from his […]
Can we agree on something? Marijuana-related businesses face a lack of banking support. This is understandable since it is still illegal on the federal level. However, this also means that money is being spent on cannabis and those customers have nowhere to bank their money, or more likely, they are banking it with you but […]
