Mapping Out a Strategic Approach to BSA/AML Compliance Before, During, and After a Financial Institution Merger

Mapping Out a Strategic Approach to BSA/AML Compliance Before, During, and After a Financial Institution Merger

Mergers of Financial Institutions (FIs) are an increasingly common industry trend. A merger creates a number of challenges for Bank Secrecy Act (BSA) Officers who are tasked with developing an integration plan, while ensuring ongoing compliance with the relevant laws and regulations. When FIs find themselves in the midst of a merger, developing a strategic approach to help facilitate the merging of policies, procedures, and processes, while simultaneously remaining compliant with applicable laws and regulations, can prove highly beneficial. 

Terrorism Financing: Past, Present and Future

Terrorism Financing: Past, Present and Future

Recently, we observed the sixteenth anniversary of 9/11, recalling the tragic loss of life and the sustained terror threat that still exists. In this article, we will recall what was believed to be one of Al Qaeda’s (“AQ”) primary means of funding its operations, discuss the current state of terrorism financing, and take a glimpse at what the future may hold.

Risky Business: A Responsible Evaluation of Enterprise-Wide AML/OFAC Risk

Risky Business: A Responsible Evaluation of Enterprise-Wide AML/OFAC Risk

How effective is your financial institution (“FI”) at assessing the overall inherent risk within your organization? Where is the highest amount of risk concentrated within the enterprise? How is risk even assessed? The responses to these questions all converge to one locale—the foundation for maintaining and safeguarding the integrity of your FI begins and ends with your AML and OFAC Enterprise-Wide Risk Assessment (“ERA”). In this post, we examine the mechanism behind developing a resilient ERA and how FIs can effectively sustain a low-risk enterprise utilizing a methodical framework. Although you may think your institution maintains a strong ERA, this post may prompt you to reexamine your ERA.

Anti-Money Laundering Legislative Reform: A Global Response to Financial Crime

Anti-Money Laundering Legislative Reform: A Global Response to Financial Crime

Financial crimes are a global epidemic, serving as a constant reminder that crime does not discriminate and cannot be contained at the border. If you recall from our last article, 'Threat Finance Spotlight on the Democratic People's Republic of Korea', illicit actors are rapidly unearthing new tactics, techniques, and procedures (“TTPs”) to gain access to and exploit the financial system. How is the world responding, as a result? Surprisingly, in unison. There has been a broad global consensus pertaining to the necessity of anti-money laundering (AML) laws and regulations.

August 2, 2017 Webinar

August 2, 2017 Webinar

What goes into designing, implementing, and sustaining a high performing Financial Intelligence Unit (FIU)? With the Association of Certified Financial Crime Specialists (ACFCS), join AML RightSource leaders Vic Maculaitis, Anthony Lear, and John Wintrow on Wednesday, August 2nd 1:00 - 2:00 PM EST to learn more.

Threat Finance Spotlight on the Democratic People's Republic of Korea

Threat Finance Spotlight on the Democratic People's Republic of Korea

In this post, we closely examine the current global threat environment and more specifically, the innovative tactics, techniques and procedures (“TTP”) exploited by illicit actors to launder US funds through evasion of US economic sanctions against the Democratic People’s Republic of Korea (“DPRK”). Ask yourself as you read this article whether or not your FI’s AML and OFAC compliance programs have the appropriate safeguards in place to avoid such exploitation.

Developing an Anti-Money Laundering Transaction Monitoring Strategy

Developing an Anti-Money Laundering Transaction Monitoring Strategy

Are all rules created equal? How do you design effective transaction monitoring rules that are capable of capturing the vast majority of money laundering and related illicit activities? In this post, we take a closer look at a US financial institution’s (“FI”) AML transaction monitoring environment. Specifically, we examine how an FI can ensure comprehensive transaction risk coverage by utilizing a targeted top-down approach in the development of its monitoring rules.

Anti-Money Laundering Look Back and Remediation Projects

Anti-Money Laundering Look Back and Remediation Projects

Where do look back and remediation projects arise from? What are the typical root causes leading to a look back or remediation project? What are the pitfalls of a look back or remediation? How do you create a winning strategy on how to approach a look back or remediation? 

This post explores the answers from an insider’s perspective of dealing with some of the most sensitive and interesting look backs of the last 11 years.