SAR Narratives for Reporting Suspected Human Trafficking
In this installment of AML Voices, John Byrne, AML RightSource Executive Vice President, Sara Crowe, Strategic Initiatives Director, Financial Systems – Polaris, and Angel Nguyen Swift, Head of Conduct Management at Wells Fargo, discuss the elements of effective SAR narratives and how to prepare them so they are most useful to law enforcement.
The AML Community List - 2021: What will be Out and In for the Upcoming Year?
I have always enjoyed The Washington Post’s (and I am sure various other publications) list for the next year. The uniqueness is, of course, they eliminate a popular or hot issue with a new one for the next calendar year. To say 2020 was different would be a vast understatement. What was clearly the most chaotic and challenging time for the entire world will, in most cases, sadly stay with us for a long time to come. The following are my (and mine alone) predictions for 2021, which is extremely foolish given what we just went through (and are still dealing with), but limited to AML related issues and themes. As David Letterman would have said, this is only an exhibition, not a competition -- so please, no wagering…
Emerging Trends in Combatting Human Trafficking
In this installment of AML Voices, John Byrne, AML RightSource Executive Vice President, Sara Crowe, Strategic Initiatives Director, Financial Systems – Polaris, and Angel Nguyen Swift, Head of Conduct Management at Wells Fargo, discuss emerging trends in combatting human trafficking. They look at the efforts to have PornHub improve its content moderation practices; the increase in online sexual exploitation during the pandemic; and financial indicators of online child sexual exploitation.
2020—AML Year End Review and What will 2021 Bring?
Ball of Confusion[i] Having been in what we call the AML community for close to 35 years, it was always clear to me that a “year-in-review” is both arbitrary and doesn’t really give you a cohesive sense of themes. However, everyone does it so here goes:
Secondary and Sectoral Sanctions: A Transformation in the Application of US Economic Sanctions
The economic sanctions administered and enforced by the US. Department of the Treasury’s Office of Foreign Assets Control (OFAC) are key foreign policy tools of the United States. OFAC sanctions draw their strength and extensive global influence from the US Dollar being the dominant currency in the cross-border world economy. The force and authority of US economic sanctions are frequently misinterpreted as the US exercising extraterritorial law. This is not the case.
These Bibles are NOT the King James Version
How do criminals learn advanced money laundering and fraud methods? This question has many answers, but in 2020 many criminals are buying this knowledge online. The information is contained in multiple files distributed through file sharing sites that are known to be havens for pirated material. The immense stress the world is experiencing due to the pandemic allows these criminals to operate more freely. Many boast on social media about their alleged gains, enticing others to purchase a copy for less than $100. These manuals are known as “fraud bibles” and have been circulated for years on the dark web, and in forums devoted to illicit activity.
FinCEN’s Updated Guidance on §314(b)
Information sharing in the BSA/AML space is a topic of ongoing discussion and such an essential tool. I wrote about the value and the challenges in a prior post. One part of the US information sharing regime is Patriot Act §314(b).[1] Since its passage, FinCEN has issued guidance about the section on a number of occasions; the most recent in December 2020 through the issuance of an updated Fact Sheet. Section 314(b) established a process for financial service companies[2] (FIs) to share certain information under the protections of a safe harbor from liability for privacy law violations or from sharing false information. Participation under §314(b) is voluntary.
