Introduction As outlined in Section 352 of the USA PATRIOT Act, which stands for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001.”, an Anti-Money Laundering (AML) Program shall establish “an ongoing employee training program…”.[1] Collectively speaking, regulatory bodies have not explicitly defined what this […]
When FinCEN issued their AML/CFT (Anti-Money Laundering/Combating the Financing of Terrorism) Priorities on June 30, 2021 1, one of those priorities was proliferation financing. But what exactly is “Proliferation Financing” and how should financial institutions manage this risk? FinCEN did not really give much insight into any of the priorities or indicate what they expect […]
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 […]
