Elliot Berman

Mr. Berman serves as marketing advisor and thought leader for AML RightSource. He is an expert in anti-money laundering compliance and a frequent conference speaker; he also has extensive experience in issues that affect business organizations and financial institutions. These areas of focus include corporate governance, banking regulation, financial data processing, risk management, payments, and e-Commerce.

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FinCEN on “Pig Butchering”

The Financial Crimes Enforcement Network (FinCEN) has issued an Alert, FIN-2023-Alert005, on the virtual currency investment scam known as “pig butchering.”[i] The Alert lays out the methodology of the scheme and provides red flags to help identify...

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Payroll Tax Evasion and Workers’ Compensation Fraud – What to Watch For

Payroll tax evasion and workers’ compensation fraud are multi-million-dollar problems in the US construction sector. Especially as many of these...

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Terrorism in the EU

Terrorism and extremism are continuing global threats. Europol assists member states in the European Union (EU) with their anti-terrorism and...

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New Guidance on Third-Party Risk Management for US Banks

The federal banking regulators have issued interagency guidance on managing the risks of working with third parties. The new guidance finalizes the...

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Improving Efficiency and Your Financial Crimes Program

Are you responsible for a financial crime compliance program? If so, one of the things that keeps you up at night is how to improve the efficiency of...

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The Long Journey to Ownership Transparency

Money launderers and criminals have used opaque corporate structures to hide and move ill-gotten gains for years. Such structures are also a haven...

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FATF’s View of the Risks of Real Estate

The Financial Action Task Force (FATF[1]) recently updated its Risk-Based Approach Guidance for the Real Estate Sector. This update was prompted by...

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Global Impact of Human Trafficking

Trafficking in persons is the second largest black market in the world (the first is the illegal drug trade). It is estimated that human trafficking...

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Elder Financial Exploitation – A Problem That Isn’t Going Away

Elder Financial Exploitation (EFE) is a global problem and is on the rise. One of several forms of elder abuse, this type includes theft, fraud, and...

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Understanding European Crypto-Assets Regulation (MiCA)

After two years of discussion and negotiation, the European Parliament and the European Council reached a provisional agreement on the Markets in...

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Has the Time Come for Adoption of Digital Asset Legislation in the US?

U.S. Senators Kirsten Gillibrand (D-NY) and Cynthia Lummis (R-WY) have introduced the Responsible Financial Innovation Act (also being referred to as...

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FinCEN Wants Your Comments on How to Regulate Real Estate

The Financial Crimes Enforcement Network (FinCEN), a bureau of the US Treasury Department, wants your help in deciding how to bring more of the real...

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Where is FinCEN on Virtual Currencies?

Virtual currencies (sometimes referred to as cryptocurrencies) continue to move into established commerce. The number of merchants accepting the...

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FinCEN’s Updated Guidance on §314(b)

Information sharing in the BSA/AML space is a topic of ongoing discussion and such an essential tool. I wrote about the value and the challenges in a...

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Fraud: In Stock for the Holidays

Every year, fraud on consumers, sellers, and financial service providers increases during the holiday shopping season. This year, pandemic conditions...

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Boards Can’t Exercise Oversight Without the Right Information

This post is part of our occasional series on AML program fundamentals which focuses on refreshing foundational knowledge for experienced members of...

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What are the Cybercriminals Up to Now?

The Financial Crimes Enforcement Network (FinCEN[1]) has issued an advisory[2], providing guidance and red flags for cybercrime and cyber-enabled...

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How Helpful is the Latest FinCEN Guidance on Customer Due Diligence?

FinCEN has issued additional guidance about the responsibility of financial services companies (FIs)[1] relating to customer due diligence (CDD). The...

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Elder Financial Exploitation is a Financial Crime

The title of this post may seem obvious, but do you know what your financial services company should be doing to detect, report and prevent it? As...

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Fraud – It Continues in Bad Times and Good

There has been a lot of information circulating about fraud during the pandemic. Many organizations, including AML RightSource, have discussed this...

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Investigations – they all start with context

This post is part of our occasional series on AML program fundamentals which focuses on refreshing foundational knowledge for experienced members of...

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Information Sharing – the Value and the Challenges

Information Sources

Financial service companies (FIs) have a wide variety of information about their customers. Some of it is personal data, gathered...

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Challenges for Community FIs Participating in the PPP Loan Program

A mixture of government assistance, and exponential increase in need on behalf of customers, and the continuous need to remain compliant has left...

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FinCEN Guidance in Response to the COVID-19 Pandemic

The operating landscape during the COVID-19 pandemic is constantly changing. The Financial Crimes Enforcement Network (FinCEN[1]) has issued guidance...

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COVID-19 Fraud Schemes

When a crisis arises, the volume and speed of activity increases causing many people to act with less care and caution. This rapid action mode opens...

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