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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.

3 min read

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 increasing risks of money laundering and terrorist financing (ML/TF) using real estate transactions....

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2 min read

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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2 min read

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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2 min read

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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3 min read

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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2 min read

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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3 min read

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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3 min read

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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3 min read

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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3 min read

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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3 min read

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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2 min read

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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2 min read

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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3 min read

Confidential means CONFIDENTIAL!

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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Libra Hero

3 min read

A Quick Look at Facebook’s Cryptocurrency Announcement

Everybody Needs Money. That’s Why They Call It Money*

On June 18th Facebook announced plans to introduce a digital wallet (named Calibra) in 2020 for...

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The-five-Ws

2 min read

Writing a useful SAR narrative

Beginning with this post we will periodically be revisiting essential AML compliance topics. Refreshing the fundamentals and AML priorities helps us...

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