The Nexus between Organized Crime and Terrorism

By John Wintrow | March 15, 2018
In past articles, we have discussed the tactics, techniques and procedures used by transnational organized crime (“TOC”) and foreign terrorist organizations (“FTO”); however, we have yet to discuss the alliance between the two, including the role the financial industry plays.

Terrorism Financing: Past, Present and Future

By John Wintrow | October 20, 2017
Recently, we observed the sixteenth anniversary of 9/11, recalling the tragic loss of life and the sustained terror threat that still exists. Numerous articles pertaining to the anniversary have been published; however, little has been written from a financial crimes perspective. In this article, we will recall what was believed to be one of Al Qaeda’s (“AQ”) primary means of funding its operations, discuss the current state of terrorism financing, and take a glimpse at what the future may hold. Past It is a common falsehood that Usama Bin Ladin (“UBL”) funded AQ from his private coffers. In reality, AQ’s war chest, according to the 9/11 Commission, pre-and-post 9/11, was believed to be between $25 to $30 million a year. The Commission also approximated UBL’s annual family inheritance to be around $1 million, which was clearly not enough to fully fund AQ’s operating budget.

Developing an Anti-Money Laundering Transaction Monitoring Strategy

By John Wintrow | June 13, 2017
Are all rules created equal? How do you design effective transaction monitoring rules that are capable of capturing the vast majority of money laundering and related illicit activities? In this post, we take a closer look at a US financial institution’s (“FI”) AML transaction monitoring environment. Specifically, we examine how an FI can ensure comprehensive transaction risk coverage by utilizing a targeted top-down approach in the development of its monitoring rules. Crafting precise and simultaneously effective monitoring rules or detection scenarios can be a tricky business. While some FIs account for multiple elements within their rules, some prefer to preserve simplicity. Some FIs may house 20-40 monitoring rules, and others boast hundreds. You have to ask yourself as an FI at some point if there is indeed a method to the madness. There actually does exist a very methodical approach in designing sound and effective transaction monitoring rules that will appropriately detect potentially suspicious activity.

Transnational Trade-Based Money Laundering

By John Wintrow | December 28, 2016
Transnational Trade-Based Money Laundering ("TBML") constitutes one of the most challenging and malevolent forms of money laundering to investigate. According to Immigration and Customs Enforcement ("ICE"), "Criminal organizations frequently exploit global trade systems to move value around the world by employing complex and sometimes confusing documentation associated with legitimate trade transactions." The flagrant volume of the criminal activity has resulted in ICE establishing the Trade Transparency Unit, designed to target transnational trade-based money laundering worldwide. This shouldn't surprise you, since criminals are now seeking novel and creative means to effectuate money laundering and subsequently escape detection. Your financial institution's BSA/AML program will be strengthened and benefit tremendously if you undertake efforts to educate employees on key elements of TBML to pay attention to in their daily money laundering investigations. Reputational risk at your financial institution will also remain minimized with a focus on extinguishing egregious and often disregarded methods of money laundering, as these criminals will ultimately be coerced into locating other outlets to perpetuate their illicit behaviors.
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Podcasts

In this episode of AML Conversations, John sits down with Sara Crowe, Strategic Initiatives Director, Financial Systems for the Polaris Project. Sara...

In this episode of AML Conversations, John sits down with David Briggs,  CEO and Co-Founder of GeoGuard and GeoComply. Beyond IP, the role of...

Welcome to This Week in AML - the weekly podcast series hosted by AML RightSource staff for financial crimes professionals. Each week we will discuss...

In the second episode of our AML Conversations series with members of IRSCI, John Byrne sits down with Greg Monahan, IRS Supervisory Special Agent of...

Welcome to This Week in AML - the weekly podcast series hosted by AML RightSource staff for financial crimes professionals. Each week we will discuss...

In this episode of AML Conversations, John Byrne sits down with Steve Gurdak, Group Supervisory of the Northern Virginia Financial Initiative, to...

In this episode of AML Conversations, John Byrne sits down with Gary Shiffman, Founder and CEO of Giant Oak and professor at Georgetown University,...

Welcome back to another episode of AML Conversations. With the recent upgrade to the US evaluation by FATF because of  the 2018 CDD rule, there has...

In this episode of AML Conversations, John Byrne sits down with Amit Sharma, CEO of Finclusive to discuss the global problem of financial access from...

Marilu Jimenez of FINCAdvisors sits down with Andy Fernandez, partner at Holland & Knight and a leading expert in sanctions compliance. They discuss...

Press

To support company growth, AML RightSource recently designed and opened an office in Highland Hills, OH. The newly renovated 43,602 square foot space...

CLEVELAND, Ohio – February 10, 2020 – AML RightSource, a leading firm focused on fighting financial crime for its clients and the world, today...

AML RightSource, a leading firm solely focused on Anti-Money Laundering (AML)/Bank Secrecy Act (BSA) and financial crimes compliance solutions, today...

AML RightSource, a leading firm solely focused on Anti-Money Laundering (AML)/Bank Secrecy Act (BSA) and financial crimes compliance solutions, today...

Our Advisory Board member Rick Small, and AML RightSource Vice Chairman John Byrne have led a multi-year effort resulting in the “Consortium for...

AML RightSource is pleased to announce the formation of its Inaugural Advisory Board to convene semi-annually starting in the first quarter of 2019.

Company’s Expansion into New York State Will Create 100 jobs in Western New York

AML RightSource is pleased to announce Timothy White, CAMS has joined the company as Vice President of Business Development and Sanctions.

AML/BSA Compliance Veteran to Expand Company’s Financial Crimes and Compliance Operations

AML RightSource, national leader in anti-money laundering services and premier provider to the financial services sector, celebrates a period of...