As with any payment network, the ACH Network sees its share of fraudulent transactions. Fraudsters have set their sights on complex schemes that utilize Account-to-Account (A2A) transfers to funnel laundered money. Scenario One: The Mule Convinced she is in love with someone she met through an online dating website, Jane agrees to accept deposits […]
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!
Human Trafficking Monies Hiding in Your Bank
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 […]
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 […]
All About BSA Risk Assessments
A Brief Summary Oddly, despite its significance in the BSA/AML/CFT/OFAC Compliance universe, the BSA Risk Assessment has no statutory requirement even though it is the foundation of any Compliance Program. As compliance professionals, we construct our transaction monitoring systems, OFAC filtering programs, and our whole Compliance Programs, on the risks that we have determined based […]
Have I Thought of Everything When It Comes to OFAC?
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 […]
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 […]
2020: The Year of Acting Unilaterally
A core tenet of economic sanctions is that they are more effective when they are imposed multilaterally, as that presents fewer alternatives for the targeted parties to continue their sanctioned activities. The past year, however, has shown few, if any, attempts at coordinated action. In fact, if anything, 2020 was more of a year in […]
Human Trafficking, Human Slavery, Trafficking in Persons, Human Smuggling – Part 2
A global problem. What can we do as US financial institutions to help bring it to an end? Last month we discussed the global blight of human trafficking under its various names. It is second only to global drug trade in terms of its profitability for the criminals who traffic in persons. It produces well […]
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 […]