Your trusted source for financial crimes compliance programs

One of the many challenges for financial crimes professionals is deciding when outside assistance is needed. In the complex and constantly changing environment of financial crimes compliance, even the largest financial service companies do not have in-house expertise in all needed functions.

When you need new perspectives or insights, you want to turn to a trusted provider. At AML RightSource, Financial Crimes Advisory can be that trusted source.



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How to Interpret the New Joint Statement on Enforcement of BSA/AML Requirements

One of the continuing challenges for Anti-Money Laundering (AML) professionals is how to explain to boards, senior management and all staff the regulatory and legal expectations for financial institutions under all of the various AML requirements. Many complaints come from business lines on compliance processes and the need for proper allocation of resources that are not designed for revenue enhancement. The federal banking agencies (FBAs) and National Credit Union Administration (NCUA) have released an update to a previous statement from 2007 and while they indicate that this announcement does not create “new expectations or standards,” let’s take a look at the areas of focus in how the FBAs will assess Cease and Desist Orders (C&D’s) and other actions.

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Independent Testing – Getting this Five Pillar Requirement Right

The reputation of a financial institution (FI) relies heavily on the conceptual soundness of its BSA/AML compliance program. Furthermore, the integrity of a FI’s compliance department depends on its ability to identify gaps and deficiencies in its compliance program. A functional way to identify gaps and deficiencies in a BSA/AML compliance program is through independent testing (one of the five pillars of an effective BSA/AML compliance program).1

The purpose of independent testing is to assist the organization’s Board of Directors when evaluating the soundness of their FI’s compliance program, and to identify areas for remediation. However, it can be difficult for FIs to understand the elements of independent testing, especially when conducted by a consultant or independent firm. Let’s examine several features of independent testing and what to look for when selecting an external company to conduct one for your FI.

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     131 CFR §1020.210(b)(2)



Planning for a New AML/Anti-Fraud/Sanctions Automation System

Picture this: your financial services company has made the decision to change AML/Anti-Fraud/Sanctions Transaction Monitoring Systems (System)! As the project manager, you have been tasked with a time intensive job and have much to account for between now and going live on the new system. Great, so now what? Successful migration projects all require; planning, communication, execution and documentation. Let’s look at some of the key elements that should be incorporated into your FI’s System migration roadmap. After you have established the project roadmap you can align it with the formal timeline of milestones for the project.2

Read more here.

     2Avoiding “Vendor Pinch” when migrating to a new AML/Anti-Fraud/Sanctions Automation System, March 27, 2020



Machine Learning and Robotic Process Automation: The Next Steps in AML Technology

Since the passage of the Bank Secrecy Act in 1970, FIs have looked for ways to automate elements of their AML compliance programs. Early automation included integration of exemption lists with teller systems, automatic printing of CTRs, accumulation of CTR information for bulk filing, integrating OFAC list screening with transaction processing systems and use of rules based systems to identify potentially suspicious transactions. More recently with the broadening of FI delivery channels, the rising cost of meeting regulatory mandates and the increasing maturity of Artificial Intelligence (AI), FIs are exploring (and in some cases deploying) new tools to enhance their AML compliance efforts.

Read more here.


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Data Integrity (Model Validation)

Over the last 15 to 20 years, automated transaction monitoring systems have progressed from the realm of the megabanks, to AML monitoring systems at all but the smallest institutions. They are a key resource for your institution’s AML/Anti-Fraud/Sanctions compliance program. As these systems have progressed, improved and become more commonplace, one element has remained unchanged; the key to their effectiveness is the quality and the completeness of the data they receive and the utilization of this data by the monitoring system. In making this analysis, start by looking at what information your AML system can utilize to maximize its detection and reporting capabilities. It’s all about the data.

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Overcoming Common Challenges When Updating a Risk Assessment

An Enterprise Wide Risk Assessment (EWRA) enables FIs to assess their BSA/AML risk profile, incorporate appropriate risk management processes, and maintain adequate controls to mitigate risk. Moreover, the FFIEC requires all FIs to maintain an EWRA. Management is responsible for communicating the EWRA to the Board of Directors. The Board, in turn, is required to ensure that the FI has adequate resources both human and technological to address the identified risk areas.

Even mature BSA/AML programs struggle to maintain a proper EWRA. Here are four common challenges FIs face in updating their AML/BSA Risk Assessments:

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How Financial Crimes Advisory Can Help You

In this edition of AML Conversations, AML RightSource Vice Chairman John Byrne sits down with Chuck Taylor, EVP and Head of the Financial Crimes Advisory practice at AML RightSource and his team of consultants to discuss the talents and services they bring to assisting clients with their BSA/AML compliance programs and AML strategies.





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