As a follow up to last month’s article “How Correspondent Banking Became a Nightmare for Foreign Banks”, and given the recent hefty penalties imposed on Habib Bank in New York, we thought it would be valuable to provide guidelines and practical solutions for minimizing the residual risk of Foreign Correspondent Banks (“FCB”). We hope the […]
In recent years, Arab banks, specifically, have suffered unique pressure from global banks to limit their access to correspondent banking relationships. The reasons are primarily a result of its susceptibility to money laundering and terrorist financing. What’s more, banking regulators in the international banking arena are encountering heightened concern among the international banks in order […]
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 […]
There has been much discussion recently among AML professionals about the future role Artificial Intelligence (AI) will play in the Anti-Money Laundering / Anti-Financial Crime arena. Most of the conversation has been directed to the prospect that AI technology will one day be able to detect, and perhaps even predict, complex relationships between financial transactions […]
On June 16th, President Donald Trump, to much fanfare, announced he was “canceling the last administration’s completely one-sided deal with Cuba”. Despite the implication that the changes to the Cuban sanctions program made over the prior two years by the Obama Administration would be largely reversed, a closer look reveals that the changes are significantly more […]
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 […]
Introduction AML professionals across the board have been sitting on the edge of their seats waiting for how President Donald J. Trump and his administration will mold the financial and political landscape in the coming years. Whichever direction he steers the boat, the AML community will need to be on their toes to anticipate any […]
On March 1, 2017, the New York State Department of Financial Service’s (the “DFS”) final cybersecurity regulations became effective (see 23 NYCRR § 500). These rules were originally published on September 13, 2016. Just before the end of the year, the DFS published another proposed regulation that eased somewhat the requirements of the original proposal […]
Data Validation is a Compliance Responsibility Are you, as Compliance Officer, prepared to certify that the data feeds into your AML monitoring and OFAC filtering systems are working properly? Identifying all data sources, properly mapping data feeds and validating data flows into the AML and OFAC monitoring/filtering systems require the collaboration of Compliance, IT and […]
It’s that time of year, scheduling the independent review. You call your provider, discuss available dates for the onsite visit and request the proposal of a new provider or if your provider is returning, the engagement letter. The proposal or engagement letter will outline the who, why, what, when, and where, much like we see […]
