How FIs can Disrupt the Child Pornography Criminal Enterprise

By AML RightSource | November 20, 2017

Crimes against children are heinous and known to be vilified even among the most notorious criminals, but these crimes are, unfortunately, also extremely profitable. The child pornography (CP) industry is a criminal business enterprise with far-reaching consequences for its victims. In a world of increasingly fast-paced, global, and anonymous transactional options, financial crimes professionals have a unique opportunity to see what others cannot, and a responsibility to aggressively research, report, and document child sexual exploitation.…

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Strategic BSA/AML Compliance in a Financial Institution Merger

By Samantha Mucha | November 1, 2017

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. A merger impacts all aspects of the FI’s BSA Program, from the Enterprise-Wide Risk Assessment (ERA) through process implementation. When FIs find themselves in the midst of a merger, developing a strategic approach…

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Terrorism Financing: Past, Present and Future

By John Wintrow | October 20, 2017

Recently, we observed the sixteenth anniversary of 9/11, recalling the tragic loss of life and the sustained terror threat that still exists. Numerous articles pertaining to the anniversary have been published; however, little has been written from a financial crimes perspective. 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…

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A Responsible Evaluation of Enterprise-Wide AML/OFAC Risk

By Sabeen Baakza | September 15, 2017

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…

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AML Legislative Reform: A Global Response to Financial Crime

By Samantha Mucha | July 31, 2017

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…

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

By Sabeen Baakza | July 10, 2017

Last time we detailed a methodical approach for US financial institutions (“FI”) in the development of an effective anti-money laundering (“AML”) transaction monitoring strategy, concluding with tuning and optimization of the AML monitoring environment. But why is frequent and ongoing tuning and optimization of monitoring rules and/or detection scenarios essential? 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…

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Developing an Anti-Money Laundering Transaction Monitoring Strategy

By John Wintrow | June 13, 2017

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. Crafting precise and simultaneously…

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AML remediation project and look back

By Vic Maculaitis | February 1, 2017

Where do look back and AML 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…

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Employee Recognition

By AML RightSource | January 27, 2017

This month AML RightSource started a new initiative to recognize employees who are going above and beyond. Employees who are recognized each month for their efforts are called “Rock Stars”.   John Ellis, Partner of AML RightSource, is heavily involved in talent acquisition and personnel development at the firm. He is always looking for ways to make AML RightSource a better place to work and is excited about the new program.  “When it comes right…

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Transnational Trade-Based Money Laundering

By John Wintrow | December 28, 2016

Transnational Trade-Based Money Laundering (“TBML”) constitutes one of the most challenging and malevolent forms of money laundering to investigate. According to Immigration and Customs Enforcement (“ICE”), “Criminal organizations frequently exploit global trade systems to move value around the world by employing complex and sometimes confusing documentation associated with legitimate trade transactions.” The flagrant volume of the criminal activity has resulted in ICE establishing the Trade Transparency Unit, designed to target transnational trade-based money laundering worldwide.…

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