FinCEN Exchange to Enhance Information Sharing Between the Public and Private Sectors

Posted by & filed under AML General.

In a news release issued yesterday, FinCEN has launched the “FinCEN Exchange” program to enhance information sharing between financial institutions and law enforcement. Per the release, “FinCEN, in close coordination with law enforcement, will convene regular briefings with financial institutions to exchange information on priority illicit finance threats, including targeted information and broader typologies.” Through… Read more »

Are you Monitoring Correspondent Banking Clients for Negative News? You Probably Should be.

Posted by & filed under AML General, Negative News, Research & Investigation.

If you have been in the AML industry for any amount of time you are aware that correspondent banking clients pose an increased risk of money laundering to a financial institution. Based on existing regulations, guidance from the Office of the Comptroller of the Currency, and industry “best” practices, financial institutions conduct enhanced due diligence… Read more »

“Paradise Papers” Topic List

Posted by & filed under AML General, Negative News.

It’s like the Panama Papers all over again!  On November 5, 2017, information on the Paradise Papers was released to the public via the International Consortium of Investigative Journalists (ICIJ – view page here).  Without a doubt, financial institutions and banks are scrutinizing these documents for client, account, and transactional exposure. A quick overview of the… Read more »

An Easy Way to Speed Up AML Work

Posted by & filed under AML General, Negative News.

At my twin daughters’ 7th grade back to school night last week I was forced to relive my horror of Algebra 1. As the parents walked into the classroom, the teacher handed us an index card and told us to complete the problem on the board.  “Show your work or no credit, and your kids… Read more »

AML Risks in Real Estate

Posted by & filed under AML General, Negative News.

The real estate market is hot…especially for money launderers. The purchasing of real estate with illicit proceeds is not a newly identified method of money laundering, yet it continues to be pervasive with drug traffickers, corrupt officers, and criminals. In a way, this should be one of the more difficult ways to launder funds, as… Read more »

Negative News Searching Isn’t Working (Part 2 of series)

Posted by & filed under AML General, Negative News.

Second in a series.  See part 1 here. Searching for negative news is among the most inefficient, inconsistent, and risky parts of AML. Whether new customer KYC, high-risk customer EDD, or suspicious activity investigations, negative news searching involves too many systems, too many manual steps, and too much likelihood something critical is missed. No wonder… Read more »

AML is Plagued by Inefficiency (Part 1 of series)

Posted by & filed under AML General, Negative News.

This is the first post in a series addressing inefficiencies in current AML processes and practical solutions to the most prevalent issues. I spend my days speaking with AML Officers, FIU Directors, and the investigators and analysts that spend their days completing EDD reviews, transaction monitoring analysis, and case investigations. I can distill those hundreds… Read more »

AML Programs for Broker-Dealers – SEC and FINRA say One Size Does Not Fit All

Posted by & filed under AML General, Negative News.

The SEC and FINRA announced that broker-dealer anti-money laundering (“AML”) programs continue to be a focus and priority for 2017. While most, if not all, broker-dealers likely have some form of AML program, this continued focus by the SEC and FINRA indicates that having just any program is not enough. Key Aspects for an AML… Read more »

AML Officers Gone Wild!

Posted by & filed under AML General.

Last week 11 individuals were charged with laundering more than $40 million in drug proceeds back to Mexico through Atlanta-area money remitters.  What makes this case unusual is that 6 of the 11 individuals were directly responsible for BSA/AML compliance. There has been a recent increase in personal liability enforcement actions against compliance officers for… Read more »