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 […]
2021 Human Trafficking Suspicious Activity Report Trends
Human Trafficking Definitions U.S. law defines human trafficking (also known as trafficking in persons, trafficking in human beings, or modern slavery) as the use of force, fraud, or coercion to compel a person into commercial sex acts or labor / services against their will. The Action-Means-Purpose (AMP) model describes the federal definition of human trafficking […]
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 […]
Structuring – You’re Probably Not Getting It Right
Structuring. That old thing? Yeah, that. Some may have stopped at the title. But if you are a community bank or credit union – you are plagued day-to-day with structuring activity and alerts. Cash is still king in smaller institutions. The chances of your analysts viewing this incorrectly – and dispositioning alerts incorrectly – is […]
Rules-Based Monitoring, Alert to SAR Ratios, and False Positive Rates – Are We Having The Right Conversations?
There is a lot of conversation in the industry about the inefficiencies of “traditional” rules-based monitoring systems, Alert-to-SAR ratios, and the problem of high false positive rates. Let me add to that conversation by throwing out what could be some controversial observations and suggestions… Current Rules-Based Transaction Monitoring Systems – are they really that inefficient? […]
Flipping the Three AML Ratios with Machine Learning and Artificial Intelligence (why Bartenders and AML Analysts will survive the AI Apocalypse)
Machine Learning and Artificial Intelligence proponents are convinced – and spend a lot of time trying to convince others – that they will disrupt and revolutionize the current “broken” AML (anti-money laundering) regime. Among other targets within this broken regime is AML alert generation and disposition and reducing the false positive rate. The result, if […]
Like Area 51, SARs Are An Open Secret.
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 […]