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.

4 min read

Europe’s New AML Regulation and Directive

With the geographic selection of the AMLA’s Headquarters, many are celebrating these days. While accurate, there’s always more to the story. In this case, the news regarding the AMLA’s decision to set up camp in Germany, while important for local...

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3 min read

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...

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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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4 min read

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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4 min read

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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