A Responsible Evaluation of Enterprise-Wide AML/OFAC Risk

By Sabeen Baakza | September 15, 2017
How effective is your financial institution (“FI”) at assessing the overall inherent risk within your organization? Where is the highest amount of risk concentrated within the enterprise? How is risk even assessed? The responses to these questions all converge to one locale—the foundation for maintaining and safeguarding the integrity of your FI begins and ends with your AML and OFAC Enterprise-Wide Risk Assessment (“ERA”). In this post, we examine the mechanism behind developing a resilient ERA and how FIs can effectively sustain a low-risk enterprise utilizing a methodical framework. Although you may think your institution maintains a strong ERA, this post may prompt you to reexamine your ERA. The AML and OFAC Enterprise-Wide Risk Assessment Methodology Though many FIs possess an AML/OFAC ERA, the actual methodology for how to appropriately conduct an ERA is oftentimes absent. In fact, many FIs do not implement this critical first step with an appropriately documented ERA methodology. The ERA should not be confused with the ERA methodology. The ERA methodology is basically akin to a user-friendly handbook that enables a FI to delineate in detail its approach to the who, what, when, where, why, and how elements involved in assessing risk, such as which databases and platforms the FI will be exploiting to obtain the information necessary to conduct the ERA, or the strategic framework for how risk will be assigned.

Threat Finance Spotlight on the Democratic People’s Republic of Korea

By Sabeen Baakza | July 10, 2017
Last time we detailed a methodical approach for US financial institutions (“FI”) in the development of an effective anti-money laundering (“AML”) transaction monitoring strategy, concluding with tuning and optimization of the AML monitoring environment. But why is frequent and ongoing tuning and optimization of monitoring rules and/or detection scenarios essential? In this post, we closely examine the current global threat environment and more specifically, the innovative tactics, techniques and procedures (“TTP”) exploited by illicit actors to launder US funds through evasion of US economic sanctions against the Democratic People’s Republic of Korea (“DPRK”). Ask yourself as you read this article whether or not your FI’s AML and OFAC compliance programs have the appropriate safeguards in place to avoid such exploitation. We begin by highlighting recent examples of how US FIs have been exploited by the DPRK as vehicles for money laundering, notwithstanding US sanctions against the DPRK. We then examine how the current administration has responded to the sanctions violations and conclude with an illustration of measures you can take to maintain the financial integrity of your institution.

The Trump Era: Potential Shifts in the Anti-Money Laundering Sphere

By Sabeen Baakza | December 1, 2016
At the onset of a new administration piloted by President-Elect Donald Trump, propelled by the potential of financial deregulation and anticipated changes in the international regulatory framework, the anti-money laundering (“AML”) infrastructure hangs in the balance. Will the Joint Comprehensive Plan of Action (“JCPOA”) be disbanded by Trump, with a reversion back to stringent sanctions on financial dealings with Iran, mitigating AML risks associated with the well-known terrorism financing haven? Will we experience a deregulation in sanctions against Russia, as Trump attempts to remediate relations with Russia? Will Trump’s plan to construct a barrier between the U.S. and Mexico in an effort to curb immigration engender new money laundering concerns? These are just a few facets you may want to explore in a preemptive effort to mitigate future risk and bolster your AML strategy and program.
1

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...