The “Red Pill” Realities of Anti-Money Laundering

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? […]

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Regulation 504 and The Evolving Compliance Landscape

On June 30, 2016, the New York State Department of Financial Services (“NYS DFS”) issued the final version Rule 504, “Banking Division Transaction Monitoring and Filtering Program Requirements and Certifications.”  The Rule takes effect on January 1, 2017, with the first reporting date of April 15, 2018.  In a sense, the Rule follows upon the […]

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BSA Risk Assessment: Documenting BSA/AML Risks to Comply with Regulatory Expectations

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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Regulation 504 and The Evolving Compliance Landscape

On June 30, 2016, the New York State Department of Financial Services (“NYS DFS”) issued the final version Rule 504, “Banking Division Transaction Monitoring and Filtering Program Requirements and Certifications.”  The Rule takes effect on January 1, 2017, with the first reporting date of April 15, 2018.  In a sense, the Rule follows upon the […]

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Are You Compliant?

Compliance organizations face challenges on multiple fronts in their efforts to control anti-money laundering (AML) risk. The perpetrators of financial crimes continually seek new ways to circumvent the protections in place, putting the financial institution at reputational and financial risk. The regulators bring their broad exposure to the latest nefarious techniques to each examination in […]

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