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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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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