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 […]
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 […]
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 […]
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 […]
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. […]
