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 â 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 […]
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 […]
Sanctions are intended to exert economic pressure on targeted groups of persons and countries to either prevent conducting business as usual or, at the very least, make it more expensive to do so. It is hoped that such impediments will cause sanctioned parties to reconsider their course of action and change it. When the scope […]
There is a lot of conversation in the industry about the inefficiencies of âtraditionalâ rules-based monitoring systems, Alert-to-SAR ratios, and the problem of high false positive rates. Let me add to that conversation by throwing out what could be some controversial observations and suggestions⌠Current Rules-Based Transaction Monitoring Systems â are they really that inefficient? […]
There are very few, if any, areas of the world, let alone our country, that arenât watching an unprecedented situation unfold in front of our very own eyes. Confirmed cases of COVID-19, also known as the Novel Coronavirus, have been found in more than 80% of the worldâs countries, and new cases show up […]
Machine Learning and Artificial Intelligence proponents are convinced â and spend a lot of time trying to convince others â that they will disrupt and revolutionize the current âbrokenâ AML (anti-money laundering) regime. Among other targets within this broken regime is AML alert generation and disposition and reducing the false positive rate. The result, if […]
What It Is The general ârule of thumbâ in the AML world is that for every method that the financial industry initiates to detect and deter money laundering, the launderers devise a new way around it. We all play by the same rules and the governing authorities have gracefully published those rules so that they […]
On July 24, 2019, the OCC issued Bulletin 2019-37 Operational Risk: Fraud Risk Management Principles. In our first article in this series, we distilled the guidance down to its three component parts governance/culture, risk management, and reporting. In this article, we cover the two central components of a compliant fraud risk management program. These are […]
Part 1: Governance, Operations, Management  Introduction  On July 24, 2019, the OCC issued Bulletin 2019-37 Operational Risk: Fraud Risk Management Principles. The OCC guidance can be broken down into three components:  Governance/Culture Ethical standards and employee accountability.  Risk Management Operations Policies, procedures, processes, controls, personnel sufficient to identify, measure, monitor, and […]
Introduction In this article, I will present updated fundamentals on what is an Anti-Money Laundering (AML) model validation as defined by the Office of Comptroller of the Currency (OCC) guidance. In an effort to provide oversight on the model validation process, I will demonstrate the definition, itâs origin, how that translates to its use in […]
