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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September Employee Spotlight: Bill French

By AML RightSource | September 1, 2019

AML RightSource September Employee Spotlight: meet Bill French! Mr. French is an Associate Manager in the AML RightSource Hudson office with over three years of experience in financial crimes consulting. He has contributed to a variety of client engagements with experience in alert investigations, cases, SAR filings, EDDs, KYC validation projects, lookback investigations, training, analyst onboarding, and project management. Mr. French is currently the engagement project manager for a team of 6 analysts completing backlog…

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By John Byrne | August 28, 2019

4th Quarter of 2019—What will it take for useful action? As we approach the Labor Day weekend and the unofficial end to summer, the 2019 calendar turns to last opportunities for any successes that can be tied to this year. For the AML community, the standard calendar year doesn’t impact our work but it can dictate things such as legislation, regulation or sometimes policy. AML reform, for example, can still occur in 2020 since we…

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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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Can you take “statements” to the bank? Risk-Focused BSA? “Showdown.”*

By John Byrne | August 2, 2019

“Banks that operate in compliance with applicable law, properly manage customer relationships and effectively mitigate risks by implementing controls commensurate with those risks are neither prohibited nor discouraged from providing banking services.” (From the July 22nd Statement) “Governments and banking regulators should focus on ways they can send an appropriate message that not all NPOs are high-risk and that, with proper due diligence, FIs can open bank accounts for NPOs and provide them with banking…

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August Employee Spotlight: Chelsea Robbins

By AML RightSource | August 1, 2019

AML RightSource August Employee Spotlight: meet Chelsea Robbins! Ms. Robbins is a Management Development Program associate in the AML RightSource Cleveland office with two years of experience in financial crimes consulting. She has worked on various client engagements and has experience in both money laundering and fraud workflows. She has assisted on lookbacks, backlogs, and BAU projects that included alert investigations, cases, SARs, EDDs, and data validation. Since joining the company in 2017, Ms. Robbins…

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Data Integrity (Model Validation)

By Tim White | July 25, 2019

It’s all about the data Over the last 15 to 20 years, automated transaction monitoring systems have progressed from the realm of the megabanks, to AML monitoring systems at all but the smallest institutions. They are a key resource for your institution’s AML/Anti-Fraud/Sanctions compliance program.  As these systems have progressed, improved and become more commonplace, one element has remained unchanged; the key to their effectiveness is the quality and the completeness of the data they…

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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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Overcoming common challenges when updating risk assessment

By Mohamed Aziz | July 12, 2019

An Enterprise Wide Risk Assessment (“EWRA”) enables Financial Institutions (“FI”) to assess their BSA / AML risk profile, incorporate appropriate risk management processes, and maintain adequate controls to mitigate risk. Moreover, the Federal Financial Institutions Examination Council (“FFIEC”) requires all FIs to maintain an EWRA. Management is responsible for communicating the EWRA to the Board of Directors. The Board, in turn, is required to ensure that the FI has adequate resources both human and technological…

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The Cloak of Technology: Rising to the Challenges of Online Banking and E-Commerce

By Diane Dylinski | July 2, 2019

The last two decades have seen a virtual explosion in online financial activity. Widespread adoption of applications (apps) running on smart phones and tablets offer a new level of portability and faster funds transfers. Customers can link bank accounts, credit cards and debit cards to apps to facilitate payments from any location. The inevitable tradeoff for this convenience is that criminals are now hiding behind the cloak of technology in their attempts to quickly move…

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