Background If you have been in banking before 2001, you know that BSA compliance was much simpler and not as burdensome as it is today. When it comes to the “Bank Secrecy Act”, it is important to remember there isn’t just one law called the “Bank Secrecy Act”. It is made up of numerous laws […]
Imagine this: Nancy at ABC Credit Union calls Rayleen at MainStreet Bank to inquire about 3 large ACH transactions moving between accounts of the two financial institutions (FIs). The three transactions appeared in the transaction monitoring system at ABC Credit Union, prompting an AML investigation. Nancy suspects their member is a money mule. Rayleen at […]
Warren Buffett once said, “When people tell me they’ve learned from experience, I tell them the trick is to learn from other people’s experience.” This is true in many areas of life, especially when it comes to BSA Consent Orders. BSA (Bank Secrecy Act) and OFAC (Office of Foreign Assets Control) personnel are wise to […]
When FinCEN issued their AML/CFT (Anti-Money Laundering/Combating the Financing of Terrorism) Priorities on June 30, 2021 1, one of those priorities was proliferation financing. But what exactly is “Proliferation Financing” and how should financial institutions manage this risk? FinCEN did not really give much insight into any of the priorities or indicate what they expect […]
To begin, let’s define our topic. Financial Elder Abuse is “when someone takes or misuses another person’s money or property for the benefit of someone other than that person. For example, neighbors, caregivers, professionals, and even family or friends may take money without permission, fail to repay money they owe, charge too much for services, or not do […]
This article was first published in the NJ Bankers Magazine. For years now, financial institutions have had to focus on the prevention of money laundering. Then in 2001, after the attack on 9/11 and the passage of the USA PATRIOT ACT (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism) […]
Human trafficking is in the news more and more. When it is mentioned, many have a picture in their minds of Asian women working in nail salons. However, this stereotyping of human trafficking is deadly as it blinds people to the trafficking that occurs in their own local community and the ill-gotten monies that may […]
This is one of those questions that keep OFAC Officers up at night. Due to the complexity of the OFAC sanctions and the scope of application, it is a challenge to create a robust program and think of everything. However, with the potential of fines with even one violation, and the size of fines being issued for multiple violations, it is imperative that financial institutions have a strong OFAC program. A strong program must […]
If this year taught us anything, it is that we do not really know what is going to happen next. We heard about COVID-19 and then our entire way of life changed overnight. Some financial institutions were better prepared than others. For example, those who had employees working remotely when the pandemic hit, were positioned […]
Human trafficking is in the news more and more. When it is mentioned, many have a picture in their minds of Asian women working in nail salons. However, this stereotyping of human trafficking is deadly as it blinds people to the trafficking that occurs in their own local community and the ill gotten monies that […]
