Warren Buffett once said, “When people tell me they’ve learned from experience, I tell them the trick is to learn from other people’s experience.” This is true in many areas of life, especially when it comes to BSA Consent Orders. BSA (Bank Secrecy Act) and OFAC (Office of Foreign Assets Control) personnel are wise to […]
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 […]
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 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 […]
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 […]
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 […]
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 […]
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 […]
