Introduction The heart and soul of your program is your BSA (Bank Secret Act)/AML This article will define what an AML model validation is and it’s importance. We will also delve into our top ten findings of AML model validations and ways to avoid them. What is an AML Model Validation? An […]
Introduction In this article, I will present updated fundamentals on what is an Anti-Money Laundering (AML) model validation as defined by the Office of Comptroller of the Currency (OCC) guidance. In an effort to provide oversight on the model validation process, I will demonstrate the definition, it’s origin, how that translates to its use in […]
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? […]
Introduction Independent verification and validation, IVV, model validation, validation or; as Shakespeare might say, a validation by any other name is still a validation. Regardless of the name it has evolved and been redefined over time. This article will cover the origin, OCC guidance, regulatory pressure, IVV methodology, reporting, independence, and vendor due diligence in […]
In order to stay compliant with today’s financial standards, most banks utilize some type of anti-money laundering (AML) program, which includes software. These programs follow BSA, OFAC, CDD/KYC, and FinCEN 314(a) guidelines to make sure banks are following AML compliance laws on a daily basis. It’s necessary to review the software and governance program involved […]
Compliance organizations face challenges on multiple fronts in their efforts to control anti-money laundering (AML) risk. The perpetrators of financial crimes continually seek new ways to circumvent the protections in place, putting the financial institution at reputational and financial risk. The regulators bring their broad exposure to the latest nefarious techniques to each examination in […]
