Red Flags Associated with the Illegal Gold Rush
In 2016, illegal gold mining operations in Peru accounted for an estimated $2.6 billion in black market trading, surpassing cocaine as the country’s most valuable illicit export1. The bulk of this illegal mining is conducted in the depths of the Amazon by ramshackle teams of criminals; human trafficking, drug trafficking, child labor, and vast environmental destruction follow in their wake. The illegal miners use an unsophisticated method of processing, utilizing mercury to form flecks of gold into an amalgam chunk, then removing the gold by boiling and dumping the mercury wastewater back into the wild at a detriment to the local flora and fauna.
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.
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.
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.
Political Contributions: A Fact Sheet
Ready or not, election season is officially here. The chaos of politics is hard enough to keep up with on its own, without the added stress of learning the ins and outs of campaign finance laws. However, in the course of our work as AML professionals, many of us will see political donations made lawfully...as well as those which are questionable. To help us differentiate, let's look further into the various political organizations one could donate to and some of the ways those organizations can use their donations.
