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 […]

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Protecting Your Financial Institution from Terrorist Financing

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) […]

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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 incorrectly – and dispositioning alerts incorrectly – is […]

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Fighting Fraud in A2A ACH Transactions

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 […]

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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 […]

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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 […]

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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 […]

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