Human Trafficking Definitions U.S. law defines human trafficking (also known as trafficking in persons, trafficking in human beings, or modern slavery) as the use of force, fraud, or coercion to compel a person into commercial sex acts or labor / services against their will. The Action-Means-Purpose (AMP) model describes the federal definition of human trafficking […]
Background In Q4 2021, the value of all crypto-assets in circulation stood close to $3Tn. At the start of 2021, that number stood at $1Tn, and nearly a decade ago did not exist. The rapid rise of interest in crypto has stunned many skeptics. The increase of crypto-assets and associated wallets has been accompanied by […]
Introduction As outlined in Section 352 of the USA PATRIOT Act, which stands for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001.”, an Anti-Money Laundering (AML) Program shall establish “an ongoing employee training program…”.[1] Collectively speaking, regulatory bodies have not explicitly defined what this […]
When FinCEN issued their AML/CFT (Anti-Money Laundering/Combating the Financing of Terrorism) Priorities on June 30, 2021 1, one of those priorities was proliferation financing. But what exactly is “Proliferation Financing” and how should financial institutions manage this risk? FinCEN did not really give much insight into any of the priorities or indicate what they expect […]
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 […]
If a willingness to do the right thing were the fuel that powered the attack on money launderers, that initiative would be a total success. Compliance professionals, regulators and law enforcement officers are motivated, but we struggle to think outside the box and change our method of operation. It’s time for us to work together […]
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) […]
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 […]
Introduction  The heart and soul of your program is your BSA (Bank Secret Act)/AML This article will define what an AML model validation is and it’s importance. We will also delve into our top ten findings of AML model validations and ways to avoid them.  What is an AML Model Validation?  An […]
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. Â Scenario One: The Mule Convinced she is in love with someone she met through an online dating website, Jane agrees to accept deposits […]
