There is so much pressure these days to get it done right the first time… even though no BSA/AML solution or program is 100% perfect.  And if look-backs (recommended or mandated) are not completed successfully, you will find yourself in a never ending pitfall of data quality issues, growing BSA/AML requirements, changing face of risk and compliance priorities, […]
Introduction Independent verification and validation, IVV, model validation, validation or; as Shakespeare might say, a validation by any other name is still a validation. Regardless of the name it has evolved and been redefined over time. Â This article will cover the origin, OCC guidance, regulatory pressure, IVV methodology, reporting, independence, and vendor due diligence in […]
For foreign branches conducting business in the U.S., head office can sometimes be both Dr. Jekyll and Mr. Hyde. On occasion this has proved to be a problem. At times banks are faced with a bureaucracy of business, which can get in the way, and sometimes they can be pressured to make decisions with the […]
In order to stay compliant with today’s financial standards, most banks utilize some type of anti-money laundering (AML) program, which includes software. These programs follow BSA, OFAC, CDD/KYC, and FinCEN 314(a) guidelines to make sure banks are following AML compliance laws on a daily basis. It’s necessary to review the software and governance program involved […]
It’s legal, it’s not legal. To quote comedian George Carlin, “well, which one is it, have it make up its mind and come on back.” As bankers, compliance professionals and advisors, we don’t have the luxury of waiting for business opportunities, financial gains and other such pivotal moments to pass us by; and with an […]
Inherently, as a financial institution doing business every day, you capture sensitive data about your customers. That sensitive data includes customer, account, and transaction data, and is housed in your Anti-Money Laundering (AML) system, if not other places as well. Your accounting system is likely well protected from insider fraud and internet attacks, but your AML […]
Introduction On March, 3, 2015, the New York Regional Director for the FDIC, John Conneely, conducted a regulatory teleconference along with Special Activities Case Managers Kristi Keating and Rebecca Williams, which focused on BSA hot topics, trends and tips to maintain Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance. This article is intended to educate board members, […]
In late February, the Superintendent of the New York State Department of Financial Services (the “DFS”) gave a speech at Columbia Law School on the role of state banking departments in the regulation of financial institutions.  New York State has been the capital of the banking industry in the United States since before any of […]
Beyond the regulatory requirements (Federal Financial Institutions Examination Council, 2010), testing is conducting in different departments for different purposes. In the IT department you are focusing on software and system quality, bug identification and integration accuracy. The audit and compliance departments are validating the continued accuracy and compliance to policies and procedures. It is the […]
How do you know if the thresholds are set correctly in your OFAC (Office of Foreign Assets Control) Sanctions Filtering or BSA (Bank Secrecy Act) Transaction Monitoring system? Â That is certainly an important question, and a mystery in the world of anti-money laundering (AML). Commonly in the financial industry, and for the purposes of this […]
