Can you take “statements” to the bank? Risk-Focused BSA? “Showdown.”*
“Banks that operate in compliance with applicable law, properly manage customer relationships and effectively mitigate risks by implementing controls commensurate with those risks are neither prohibited nor discouraged from providing banking services.” (From the July 22nd Statement)
August Employee Spotlight: Chelsea Robbins
We are very excited to highlight a staff member each month from our team of superb employees. AML RightSource August Employee Spotlight: meet Chelsea Robbins! Ms. Robbins is a Management Development Program associate in the AML RightSource Cleveland office with two years of experience in financial crimes consulting. She has worked on various client engagements and has experience in both money laundering and fraud workflows. She has assisted on lookbacks, backlogs, and BAU projects that included alert investigations, cases, SARs, EDDs, and data validation.
Data Integrity (Model Validation)
It’s all about the data Over the last 15 to 20 years, automated transaction monitoring systems have progressed from the realm of the megabanks, to AML monitoring systems at all but the smallest institutions. They are a key resource for your institution’s AML/Anti-Fraud/Sanctions compliance program. As these systems have progressed, improved and become more commonplace, one element has remained unchanged; the key to their effectiveness is the quality and the completeness of the data they receive and the utilization of this data by the monitoring system. In making this analysis, start by looking at what information your AML system can utilize to maximize its detection and reporting capabilities; it’s all about the data.
A Quick Look at Facebook’s Cryptocurrency Announcement
Everybody Needs Money. That’s Why They Call It Money* On June 18th Facebook announced plans to introduce a digital wallet (named Calibra) in 2020 for use with a new digital currency, named Libra. As part of the announcement, the company issued a white paper from the Libra Association, a non-profit formed to govern the currency. The association includes a wide variety of entities in the payments, technology, telecommunications, blockchain and venture capital industries. Notably absent from membership at the time of the announcement were any large financial institutions.
Overcoming common challenges when updating risk assessment
This post is part of our occasional series on AML program fundamentals which focuses on refreshing foundational knowledge for experienced members of the AML community and providing an introduction to key topics for those new to the subject. An Enterprise Wide Risk Assessment (“EWRA”) enables Financial Institutions (“FI”) to assess their BSA / AML risk profile, incorporate appropriate risk management processes, and maintain adequate controls to mitigate risk. Moreover, the Federal Financial Institutions Examination Council (“FFIEC”) requires all FIs to maintain an EWRA. Management is responsible for communicating the EWRA to the Board of Directors. The Board, in turn, is required to ensure that the FI has adequate resources both human and technological to address the identified risk areas.
The Cloak of Technology: Rising to the Challenges of Online Banking and E-Commerce
The last two decades have seen a virtual explosion in online financial activity. Widespread adoption of applications (apps) running on smart phones and tablets offer a new level of portability and faster funds transfers. Customers can link bank accounts, credit cards and debit cards to apps to facilitate payments from any location. The inevitable tradeoff for this convenience is that criminals are now hiding behind the cloak of technology in their attempts to quickly move funds and avoid detection. New technology gives rise to concerns regarding customer identity, exploitation of the technology, and a sharp rise in online scams.
July Employee Spotlight: David Green
We are very excited to highlight a staff member each month from our team of superb employees. AML RightSource July Employee Spotlight: meet David Green! Mr. Green is a Senior Analyst in the AML RightSource Hudson office with over two years of experience in financial compliance including quality assurance, training, project-specific analyst onboarding, analyst development, investigations, SARs, EDDs, transaction monitoring, project management assistance, and internal and external reporting.
We Can Change the World*
Working together always works While I have always believed that what we do in the AML community makes a difference, the past two years (at least) have seen the expansion of challenges that demand proactivity. When we work together with groups outside of AML toward a common goal, our impact can be immeasurable.
AML RightSource Voices – Hot Topics Webinar
AML RightSource is launching a quarterly webinar series, "AML RightSource Voices". The first installment will be broadcast live on July 23rd, 2019 beginning at 12:30 pm ET, with this edition focusing on AML Hot Topics. The discussion will include insights into the intersection of AML compliance and the art and antiquities markets, how to ensure your compliance program supports working effectively with charities, the recently published Framework for OFAC Compliance Commitments, updates on sanctions relating to Iran and North Korea, high risk customers, customer due diligence, and the pending AML legislation in the House and the Senate.
