Why EVERY Financial Institution Needs to Be a 314(b) Participant A Joint Effort from the desks of: NEACH and AML-ology

Imagine this: Nancy at ABC Credit Union calls Rayleen at MainStreet Bank to inquire about 3 large ACH transactions moving between accounts of the two financial institutions (FIs). The three transactions appeared in the transaction monitoring system at ABC Credit Union, prompting an AML investigation. Nancy suspects their member is a money mule. Rayleen at […]

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What Do I Need to Know About Proliferation Financing?

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 […]

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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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AML in the Age of Cryptocurrency (Part 1)

Introduction Virtual currency businesses get caught in the anti-money laundering (AML) web both coming and going.   Financial services businesses such as banks view them as suspect customers and suspect business partners, and either flee or impose stringent information requirements and onerous ongoing monitoring.  Meanwhile, the banks may be filing secret reports with the U.S. federal […]

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