What is explainability? There is a lot of chatter about it in relation to software applications, in particular those that leverage emerging technologies such as artificial intelligence (AI) and machine learning (ML). Regulators have been sort of blunt about use of these technologies: a firm can’t just buy and implement a new piece of technology, […]
There can be a precarious path bankers walk assuming that a community bank has a low risk for money laundering. The reality is that nefarious actors know this, and while these banks are often doing their best with the staff and budget they have to work with, bank leaders and board members need to be […]
Let’s put these numbers in perspective. 99% of laundered money is not caught. 90% of the resources spent catching suspicious actors are wasted. 100 % of US banks have known this for years. How did we get here? Modern technology, specifically data analytics, is well-suited to address this problem. Why hasn’t this problem been solved? […]
One way or another we’ve all done it. Completed the documentation, prepped the files, sent it for review and approval, and watched as the SAR we took time to support and document be dropped into that massive industrial cavern known as the governmental database. Rarely have we, or most of the analysts and advisers we’ve […]
How do these Guidance items apply to a virtual currency business located in a foreign country? On July 21, 2011, FinCEN published in the Federal Register a final rule on definitions and other regulations relating to money services businesses.[1] An entity may now qualify as a MSB under the Bank Secrecy Act regulations based on […]
Introduction Billions of dollars in fines have been paid by the banking industry for “inadequate” AML programs even though our biggest banks devote huge sums and thousands of people in their efforts to comply. The emerging virtual currency business is just getting its “toes wet” in the serious and high-stakes business of AML compliance. To make […]
As the term connotes, most people would probably think that money laundering is the process of making illicit funds appear legitimate or, more simply put, clean dirty money. In the quintessential money laundering-themed TV show, Breaking Bad, a car wash business was used to clean dirty money earned by the main character, Walter White, from his […]
Can we agree on something? Marijuana-related businesses face a lack of banking support. This is understandable since it is still illegal on the federal level. However, this also means that money is being spent on cannabis and those customers have nowhere to bank their money, or more likely, they are banking it with you but […]
Digital currency technologies generated widespread public and investor interest in 2017, with new cryptocurrency products capable of streamlining and decentralizing global commerce. Unfortunately, these technologies also create new money laundering tools that allow countries like Iran, North Korea, and Russia to evade international sanctions. This is especially true of so-called “privacy coins,” which offer personal […]
Its that time again, to revisit and amend our BSA policies, procedures, risk models and training. It seems it never ends, and it is for this very reason we are going to revisit our February 2015 article, ‘Who Owns the Money?’. I can hear it already, what now? Who changed it, why, etc, etc, etc. […]
