IRS Newswire—sometimes the best anti-fraud resources are free
I know there’s an answer[I]
Examinations During the Pandemic
No Deja Vu[1] Examiners will consider the unique, evolving, and potentially long-term nature of the issues confronting institutions and exercise appropriate flexibility in their supervisory response. Stresses caused by COVID-19 can adversely impact an institution’s financial condition and operational capabilities, even when institution management has appropriate governance and risk management systems in place to identify, monitor, and control risk.[2] We are all guilty of saying something along the lines of “wow, this has never happened before” and occasionally we are right. Next year will be twenty years since 9/11, a direct attack on the US; now we have this pandemic which is the first event of such magnitude since 1918. So, for 90% of us, this has never happened before. As such, all responses are new and there are no parallels.
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:
