Warren Buffett once said, “When people tell me they’ve learned from experience, I tell them the trick is to learn from other people’s experience.” This is true in many areas of life, especially when it comes to BSA Consent Orders. BSA (Bank Secrecy Act) and OFAC (Office of Foreign Assets Control) personnel are wise to […]
Spotlight: AML Training is a Pillar of Compliance – How are you meeting this requirement?
Introduction As outlined in Section 352 of the USA PATRIOT Act, which stands for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001.”, an Anti-Money Laundering (AML) Program shall establish “an ongoing employee training program…”. Collectively speaking, regulatory bodies have not explicitly defined what this […]
Have I Thought of Everything When It Comes to OFAC?
This is one of those questions that keep OFAC Officers up at night. Due to the complexity of the OFAC sanctions and the scope of application, it is a challenge to create a robust program and think of everything. However, with the potential of fines with even one violation, and the size of fines being issued for multiple violations, it is imperative that financial institutions have a strong OFAC program. A strong program must […]
The Science Behind False Positive Tuning
Introduction How do you know if the thresholds are set correctly in your OFAC (Office of Foreign Assets Control) Sanctions Filtering or BSA (Bank Secrecy Act) Transaction Monitoring system? That is certainly an important question, and a mystery in the world of anti-money laundering (AML). Commonly in the financial industry, and for the purposes of […]
New OCC Rules on Fraud Risk Management
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 […]
Much Ado, or Mucha Don’t?
On June 16th, President Donald Trump, to much fanfare, announced he was “canceling the last administration’s completely one-sided deal with Cuba”. Despite the implication that the changes to the Cuban sanctions program made over the prior two years by the Obama Administration would be largely reversed, a closer look reveals that the changes are significantly more […]
How Will the Trump Administration Affect Anti-Money Laundering Regulation?
Introduction AML professionals across the board have been sitting on the edge of their seats waiting for how President Donald J. Trump and his administration will mold the financial and political landscape in the coming years. Whichever direction he steers the boat, the AML community will need to be on their toes to anticipate any […]
AML & OFAC Data Validation: What Steps Must Compliance Take to Satisfy Regulatory Expectations?
Data Validation is a Compliance Responsibility Are you, as Compliance Officer, prepared to certify that the data feeds into your AML monitoring and OFAC filtering systems are working properly? Identifying all data sources, properly mapping data feeds and validating data flows into the AML and OFAC monitoring/filtering systems require the collaboration of Compliance, IT and […]
The Science Behind False Positive Tuning
How do you know if the thresholds are set correctly in your OFAC (Office of Foreign Assets Control) Sanctions Filtering or BSA (Bank Secrecy Act) Transaction Monitoring system? That is certainly an important question, and a mystery in the world of anti-money laundering (AML). Commonly in the financial industry, and for the purposes of this […]
Evolving Iranian Sanctions: Joint Comprehensive Plan of Action (JCPOA)
As part of international efforts to prevent further development of Iran’s nuclear weapons program, on December 31 2011 the United States (US) imposed various ranges of diplomatic and legal sanctions to prevent foreign financial institutions (FFI’s) from conducting transactions with Iran through the US Department of the Treasury; Office of Foreign Assets Control (OFAC) regulations. […]