Its that time again, to revisit and amend our BSA policies, procedures, risk models and training. It seems it never ends, and it is for this very reason we are going to revisit our February 2015 article, ‘Who Owns the Money?’. I can hear it already, what now? Who changed it, why, etc, etc, etc. […]
A Refreshing Look at CDD
This is the first of some articles that I will write on various BSA AML related subjects. I must warn the reader that the views expressed are my own and represent neither the views of ARC Risk and Compliance nor my former employer, the Federal Reserve Bank of New York. By way of background, my […]