Elliot Berman

The Five Pillars of an AML Compliance Program

By Elliot Berman | September 16, 2019

This post is part of our occasional series on AML program fundamentals which focuses on refreshing foundational knowledge for experienced members of the AML community and providing an introduction to key topics for those new to the subject. For many years AML compliance programs were built on the four internationally known pillars: development of internal policies, procedures and controls, designation of a AML (BSA) officer responsible for the program, relevant training of employees and independent…

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Tools for Exchanging Value

By Elliot Berman | August 16, 2019

During our first live webinar broadcast we received a number of questions from the audience which we did not have time to answer during the broadcast. One of those questions was, can you clarify how the various ways for value to be exchanged between people or businesses work? You may be familiar with some of these value transfer products, Venmo, Zelle, PayPal, Google Pay Send (formerly Google Wallet), Square Cash (also known as CashApp), Apple…

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A Quick Look at Facebook’s Cryptocurrency Announcement

By Elliot Berman | July 18, 2019

Everybody Needs Money. That’s Why They Call It Money* On June 18th Facebook announced plans to introduce a digital wallet (named Calibra) in 2020 for use with a new digital currency, named Libra.  As part of the announcement, the company issued a white paper from the Libra Association, a non-profit formed to govern the currency.  The association includes a wide variety of entities in the payments, technology, telecommunications, blockchain and venture capital industries.  Notably absent…

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Writing a useful SAR narrative

By Elliot Berman | June 3, 2019

Beginning with this post we will periodically be revisiting essential AML compliance topics. Refreshing the fundamentals and AML priorities helps us stay focused and able to absorb new ideas and trends. Writing useful narratives for Suspicious Activity Reports (SARs) can often be a struggle. When there are many transactions, involving multiple parties, over a long time period, putting together a clear explanation of the facts can be challenging. Part of the challenge is providing clarity…

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