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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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 […]

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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 […]

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Spotlight: BSA/Transaction Monitoring Software – What Your Peers Are Using, Doing, and Paying

Every quarter we conduct a survey on important topics to anti-money laundering (AML) professionals. A recent survey covered the topic of the use of BSA/Transaction Monitoring software. Although having an automated transaction monitoring software is not required for financial institutions, having a technology—whether it be a manual process through spreadsheets, or something through an automated […]

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The Science Behind False Positive Tuning

Introduction How do you know if the thresholds are set correctly in your OFAC (Office of Foreign Assets Control) Sanctions Filtering or BSA (Bank Secrecy Act) Transaction Monitoring system?  That is certainly an important question, and a mystery in the world of anti-money laundering (AML). Commonly in the financial industry, and for the purposes of […]

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The EU’s 6th AML Directive – The Inclusion of Non-Financial Companies in the Regulation Preventing Money Laundering

Shortly after the 4th AML Directive took final effect and prior to the 5th AML Directive final compliance date (3 January 2020), the European Parliament passed Directive 2018/1673 – the 6th AML Directive.  AMLD6 has a compliance date of 3 December 2020. The Directive increased the number of predicate offense categories to twenty-two.  The newly […]

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Snow Washing: What You Need to Know

What is snow washing?  Hint: it has nothing to do with the Ivory Snow Detergent washing powder. Wikipedia tells us that Snow washing refers to hiding illegitimate financial transactions often for purposes of tax evasion in Canada. The term being an amalgam of the words snow meaning purity as well as the cold Canadian climate and washing referring to money […]

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