Edward Ellis

The Dark Triad: Understanding the Growing Nexus of Organized Crime, Terror, and Fraud

By Edward Ellis | April 2, 2019

While financial institutions are familiar with the concepts of transnational organized crime (TOC) and foreign terrorist organizations (FTO), many may not be fully aware of the expanding alliances between the two. Organized crime and terrorism groups are increasingly relying on each other to create troubling, synergistic outcomes. While both groups differ in many aspects, the way they are funding themselves involve some of the same tactics and methods. The nexus between these two seemingly distinct…

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Evaluating Controls in the Risk Assessment Equation

By Edward Ellis | March 25, 2019

As the need to stay in compliance continues to be at the forefront of every financial institution’s priorities, one of the key factors is The Federal Financial Institutions Examination Council’s (FFIEC) requirement for financial institutions to develop and execute an Enterprise Wide Risk Assessment (EWRA). Beyond this requirement and the acknowledgment that the FIs may employ a risk-based approach to the EWRA, the FFIEC provides very little guidance on how to execute an effective EWRA.…

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The Beneficial Ownership Rule

By Edward Ellis | March 6, 2019

As all financial institutions are aware, in May of 2018, the Financial Crimes Enforcement Network (FinCEN) customer due diligence (CDD) Rule went into effect, amending pre-existing Bank Secrecy Act (BSA) regulations. This rule was enacted in part to help solidify customer due diligence requirements for U.S. financial institutions, and added the Beneficial Ownership Rule. Subject to certain exclusions, the rule requires that all covered Financial Institutions (FIs) collect and maintain information on beneficial owners for…

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Is AML Ready for Artificial Intelligence?

By Edward Ellis | February 14, 2019

Today’s criminals have more sophisticated ways to launder money than ever before. This is creating unprecedented challenges for the AML community. To minimize the increasing risks, financial institutions also need more advanced tools and skills to help them track, discover, and stop financial crimes from occurring. One new field of technology being explored in the fight against financial crimes is artificial intelligence. Through ongoing continuous training, machine-learning-based AI continually gathers new knowledge, becomes smarter, and…

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How to Prepare Your Company for Annual AML Exams

By Edward Ellis | February 1, 2019

When AML compliance exams come up in conversation among financial institutions, the most common word we hear is “inconsistent.” Financial leaders would like more certainty among the various regulatory bodies, including on their interpretation and enforcement of AML laws. While we have seen a lessening of AML enforcement actions, there is a clear increase in formal agency criticism. Across the board, regulatory bodies are strengthening exam enforcement in which deficiencies result in the need for…

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The Art of Money Laundering: How to Fight the Perfect Crime

By Edward Ellis | December 26, 2018

Certain works of fine art are priceless. Literally. They do not have a market-determined value. The cost is whatever an art collector is willing to pay. Price flexibility in the art market is just one of the many advantages for a certain subset of the criminals — money launderers. Other advantages include portability, lack of a paper trail, anonymity, and no regulations. Artwork is lightweight compared to other valuables, like gold and cash. Artwork is…

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Aml Best Practices That Will Help You Sleep Better at Night

By Edward Ellis | December 6, 2018

Since the horrific attacks of 9/11, and the congressional response of the USA PATRIOT Act, financial institutions have been occupied with the increasing focus on anti-money laundering (AML) compliance. This is, of course, not surprising.  The money laundering problem has grown to an estimated size of $2 trillion in ill-gotten funds. The financial sector has certainly embraced their role in preventing and detecting this vast array of crimes but the challenges of resources, training, and…

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