Here you will find the AML-ology curriculum, our monthly curated articles, to help any BSA professional stay up-to-date on the latest trends and learn answers to timeless challenges. We share articles written by a number of industry sources that we believe take an academic approach to the challenges anti- money laundering (AML) professionals face, and actual solutions for you to implement. These articles are published monthly and sent directly to you when you sign up to be an AML-ology Scholar!

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Are Sanctions Cruel?

Sanctions are intended to exert economic pressure on targeted groups of persons and countries to either prevent conducting business as usual or, at the very least, make it more expensive to do so. It is hoped that such impediments will cause sanctioned parties to reconsider their course of action and change it. When the scope […]

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Rules-Based Monitoring, Alert to SAR Ratios, and False Positive Rates – Are We Having The Right Conversations?

There is a lot of conversation in the industry about the inefficiencies of “traditional” rules-based monitoring systems, Alert-to-SAR ratios, and the problem of high false positive rates. Let me add to that conversation by throwing out what could be some controversial observations and suggestions… Current Rules-Based Transaction Monitoring Systems – are they really that inefficient? […]

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Flipping the Three AML Ratios with Machine Learning and Artificial Intelligence (why Bartenders and AML Analysts will survive the AI Apocalypse)

Machine Learning and Artificial Intelligence proponents are convinced – and spend a lot of time trying to convince others – that they will disrupt and revolutionize the current “broken” AML (anti-money laundering) regime. Among other targets within this broken regime is AML alert generation and disposition and reducing the false positive rate. The result, if […]

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Challenges and Solutions to Staffing an AML Compliance Team

In my over 35 years of providing recruitment and staffing services to the financial industry, I have been through the ups and downs of talent shortages, retention issues, and compensation variances. These are commonplace issues that occur in many departments due to economic reasons, budgets, training gaps, etc.  However, it seems that these challenges are […]

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Part 2: Your Secret Weapons in Fraud Risk Management Compliance

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 […]

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New OCC Rules on Fraud Risk Management

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 […]

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Model Validation: The definition, the origin and why you should be doing one

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 […]

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Explaining Explainability

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, […]

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