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.
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 many financial institutions (FIs) stretched thin, and scrambling. As I have written several times recently, the COVID-19 pandemic is creating a very complex operating environment for financial services companies and their customers.
AML Conversations: Chip Poncy - The Upgraded US FATF Status
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 been a debate on the appropriateness of the rating given other areas of concern. Today, John Byrne and Chip Poncy, former FATF lead from the US, discuss the criticism, and Chip offers insight into FATF, their processes and where the US stacks up with their counterparts.
Pandemic Scams - Profiting from Panic
The world is currently facing a viral pandemic that threatens personal health, employment, and financial markets. Local and national news media are tasked with issuing public service warnings and updating citizens on continuously changing rules that affect everyday life and liberty. In short, it’s an unprecedented and at times, stressful situation.
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 twice in the last three weeks. The first, issued on March 16, 2020[2] focuses on two areas – the ability of banks to timely file required Bank Secrecy Act (BSA) reports and identifying potential scams arising out of this current environment. The second, issued on April 3, 2020[3] provides information to assist FIs in complying with BSA obligations and announces a process for making direct contact with FinCEN for “urgent COVID-19 related issues.”
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.
The State of AML Practices in 2020 eBook
Where are things in the AML compliance space going? As regulatory expectations change, Congress flirts with statutory reform, and new technologies emerge, the AML compliance landscape has never been so dynamic. With today's uncertain and ever-changing space, it's worth wondering: How will AML compliance evolve in the future?
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.
Avoiding “Vendor Pinch” when migrating to a new AML/Anti-Fraud/Sanctions Automation System
Regardless of the reason for migrating to a new Anti-Money Laundering Automation System, (System) the conversion process will likely be; costly, complex, challenging, and unfortunately protracted. Here are some things to consider as you begin considering a change.
