COVID-19 Also Impacts Financial Access
“Time won’t let me”[I] The need to move quickly.. As the AML community grapples with increased fraud and financial crime during this global pandemic, previous regulatory challenges can become even more pronounced. Continuing problems that seem to be exacerbated at this time include de-risking or other limits to financial access, hurdles such as delays in funds transfers to humanitarian groups, and the chronically underbanked.
The April 2020 Updates to the FFIEC BSA/AML Manual
“Cause you know sometimes words have two meanings” [i] As the AML community clearly knows, the Federal Financial Examination Council (FFIEC) has been working for quite some time on the updates to the last iteration from 2014. Now we have the first in what promises to be a series of updates, released on tax day. The changes in wording and other modifications are encouraging, but only time will tell regarding their impact in practice.
A review of: The Economics of Violence: How Behavioral Science Can Transform our View of Crime, Insurgency and Terrorism
A View to a Kill?[i] I have said many times that AML professionals in today’s world need to evolve and change with the various ways criminals adjust their actions to fit technology, laws and policies. Part of that strategy is to read and listen to those that come up with different approaches to age-old challenges. It doesn’t mean, of course, that outside voices are right, but being open to different types of analysis is always useful in improving our ability to have a strong and vibrant AML community.
Getting by on fewer BSA Resources?
What a Fool Believes[I] Until recently, the AML community has seen only two major cases of personal liability. Frankly, many conferences and webinars have downplayed the impact of those rulings on how institutions should either allocate AML/CTF resources or give governance prominence to the BSA function.
Will 2020 bring true AML Reform?
“For what it’s worth,[1]” corruption is the key.
The Song Remains the Same*
AML Professionals simply want the BSA to work.. Whether in open hearings before Congress, at conferences, or in closed-door sessions such as our recent AML RightSource Symposium, when AML community leaders discuss their challenges, the themes are constant-the bifurcated nature of the Bank Secrecy Act prevents success. Success, as has been defined many times, is to get information into the hands of law enforcement. Over the course of the day, the group of AML leaders covered a broad range of issues including internal audit, examiners, third party vendors and technology and all seemed to arrive at the same place—much of the infrastructure surrounding AML sometimes contributes to inefficiency and misplaced allocation of resources. Some examples follow:
Time?*
4th Quarter of 2019—What will it take for useful action? As we approach the Labor Day weekend and the unofficial end to summer, the 2019 calendar turns to last opportunities for any successes that can be tied to this year. For the AML community, the standard calendar year doesn’t impact our work but it can dictate things such as legislation, regulation or sometimes policy. AML reform, for example, can still occur in 2020 since we are currently in the beginning of a two-year congressional session. Also, if there is a change in Administrations after the presidential election, some agency chairs will change, but not until early 2021, which could also include a shift in agency leadership and potential thematic or priority shifts.
Can you take “statements” to the bank? Risk-Focused BSA? “Showdown.”*
“Banks that operate in compliance with applicable law, properly manage customer relationships and effectively mitigate risks by implementing controls commensurate with those risks are neither prohibited nor discouraged from providing banking services.” (From the July 22nd Statement)
