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.
Making Suspicious Activity Reports (SARs) Useful
In this episode of AML Conversations, John Byrne, AML RightSource Executive Vice President, Chuck Taylor, AML RightSource Executive Vice President and Head of Financial Crimes Advisory, and Steve Gurdak, Group Supervisor, Northern Virginia Financial Initiative Washington/Baltimore HIDTA discuss Suspicious Activity Reports (SARs). During the conversation the look at how SARs support law enforcement investigations and what are best practices for preparing useful SARs.
Are All Charities High Risk Customers?
Are all charities high risk customers? This is an important question when thinking about de-risking and access to financial services.
Assisting NPO’s and Their Need for Financial Access
Finally, “Work to Do”[i] Having spent a good deal of my career dealing with legislation, regulations, guidance and assorted policy statements, it never ceases to amaze me how long some things take from start to finish. Of course, I have seen money laundering related legislation virtually every two years from 1986-96 and the three weeks it took to pass the USA PATRIOT Act in 2001, but other issues are not done so swiftly.
Comments to September ANPRM by FinCEN
As a contributing member of the Financial Crimes space, AML RightSource has formally submitted the comments (below) to the September ANPRM by FinCEN. After discussions with a number of our clients and other members of the AML community, we are hopeful that the themes in our letter will be useful to this important process of addressing the flaws and the need for improvement in the AML infrastructure.
