Background In Q4 2021, the value of all crypto-assets in circulation stood close to $3Tn. At the start of 2021, that number stood at $1Tn, and nearly a decade ago did not exist. The rapid rise of interest in crypto has stunned many skeptics. The increase of crypto-assets and associated wallets has been accompanied by […]
Spotlight: AML Training is a Pillar of Compliance – How are you meeting this requirement?
Introduction As outlined in Section 352 of the USA PATRIOT Act, which stands for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001.”, an Anti-Money Laundering (AML) Program shall establish “an ongoing employee training program…”. Collectively speaking, regulatory bodies have not explicitly defined what this […]
What Do I Need to Know About Proliferation Financing?
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 […]
Financial Elder Abuse: The Never-Ending Struggle to Stop It
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 […]
How Goes the War Against Laundering?
If a willingness to do the right thing were the fuel that powered the attack on money launderers, that initiative would be a total success. Compliance professionals, regulators and law enforcement officers are motivated, but we struggle to think outside the box and change our method of operation. It’s time for us to work together […]
Our Top 10 AML Model Validation Findings And How To Avoid Them
Introduction The heart and soul of your program is your BSA (Bank Secret Act)/AML This article will define what an AML model validation is and it’s importance. We will also delve into our top ten findings of AML model validations and ways to avoid them. What is an AML Model Validation? An […]
Spotlight: How Your Peers are Addressing MRBs, If They are Actually Banking Them, and How They are Mitigating the Risks Associated with Them
Every year we conduct surveys on important anti-money laundering (AML) topics. A recent survey focused on the topic of Marijuana Related Businesses (MRBs). While marijuana remains illegal on the federal level, more states have begun legalizing both adult and recreational marijuana on a state level. Although the political landscape has changed, with the Democrats controlling […]
Current Trends in Cannabis Banking and Merchant Payment Solutions
There has been a problematic lack of merchant payment solutions and access to banking services for the cannabis industry in the United States since its inception. There are many prevalent misconceptions and myths about why this gap in banking services persists, despite the growing success of the cannabis industry in the United States. While it […]
Keys to a Successful Examination
Whether we like it or not, regulatory examinations are a fact of life for all banks and bankers. Accommodating examinations from the regulators including the associated costs is something that has been dealt with for decades – some might say ad nauseum! Nonetheless, we are stuck with it! It is going to be around for […]
Human Trafficking, Human Slavery, Trafficking in Persons, Human Smuggling – Part 1: A global problem. What can we do as US financial institutions to help bring it to an end?
Consider the following: On October 23, 2019, the bodies of 39 Vietnamese people—29 men, 2 boys, and 8 women — including 10 teenagers; the youngest were two 15-year-old boys—were found in the trailer of a refrigerated trailer in Essex, United Kingdom. The trailer had been shipped from Belgium, to UK. Although it was a refrigerated […]