On July 24, 2019, the OCC issued Bulletin 2019-37 Operational Risk: Fraud Risk Management Principles. In our first article in this series, we distilled the guidance down to its three component parts governance/culture, risk management, and reporting. In this article, we cover the two central components of a compliant fraud risk management program. These are […]
Part 1: Governance, Operations, Management Introduction On July 24, 2019, the OCC issued Bulletin 2019-37 Operational Risk: Fraud Risk Management Principles. The OCC guidance can be broken down into three components: Governance/Culture Ethical standards and employee accountability. Risk Management Operations Policies, procedures, processes, controls, personnel sufficient to identify, measure, monitor, and […]
Introduction In this article, I will present updated fundamentals on what is an Anti-Money Laundering (AML) model validation as defined by the Office of Comptroller of the Currency (OCC) guidance. In an effort to provide oversight on the model validation process, I will demonstrate the definition, it’s origin, how that translates to its use in […]
What is explainability? There is a lot of chatter about it in relation to software applications, in particular those that leverage emerging technologies such as artificial intelligence (AI) and machine learning (ML). Regulators have been sort of blunt about use of these technologies: a firm can’t just buy and implement a new piece of technology, […]
There can be a precarious path bankers walk assuming that a community bank has a low risk for money laundering. The reality is that nefarious actors know this, and while these banks are often doing their best with the staff and budget they have to work with, bank leaders and board members need to be […]
BSA risks continue to evolve and time does not stand still for money launderers or fraudsters. The criminals are always looking for non-traditional ways to accomplish the same results and financial institutions and BSA Officers often only rely on controls we are most comfortable with. This tendency is the starting foundation for BSA criticism. Is your BSA program and […]
Structuring – You’re Probably Not Getting It Right Structuring. That old thing? Yeah, that. Some may have stopped at the title. But if you are a community bank or credit union – you are plagued day-to-day with structuring activity and alerts. Cash is still king in smaller institutions. The chances of your analysts viewing this […]
Introduction In my twenty years of being a BSA officer, I’ve learned a lot, both through any successes my team has had, and through the mistakes I’ve made. In this article, I’m going to share with you all the things that have stood out to me in my career: all the AML stakeholders, the full […]
Let’s put these numbers in perspective. 99% of laundered money is not caught. 90% of the resources spent catching suspicious actors are wasted. 100 % of US banks have known this for years. How did we get here? Modern technology, specifically data analytics, is well-suited to address this problem. Why hasn’t this problem been solved? […]
One way or another we’ve all done it. Completed the documentation, prepped the files, sent it for review and approval, and watched as the SAR we took time to support and document be dropped into that massive industrial cavern known as the governmental database. Rarely have we, or most of the analysts and advisers we’ve […]
