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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The Trump Era: Potential Shifts in the Anti-Money Laundering Sphere

By Sabeen Baakza | December 1, 2016

At the onset of a new administration piloted by President-Elect Donald Trump, propelled by the potential of financial deregulation and anticipated changes in the international regulatory framework, the anti-money laundering (“AML”) infrastructure hangs in the balance. Will the Joint Comprehensive Plan of Action (“JCPOA”) be disbanded by Trump, with a reversion back to stringent sanctions on financial dealings with Iran, mitigating AML risks associated with the well-known terrorism financing haven? Will we experience a deregulation…

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Anti-Money Laundering Strategy

By Vic Maculaitis | November 1, 2016

Where does your institution’s Anti-Money Laundering (“AML”) strategy place its focus? Is compliance your goal? Does your road map lead to compliance through a policy; a designated compliance officer; a system of internal controls; a training program; and independent testing? If the aforementioned are both the staples and level of meaningful thought that you have put behind your AML strategy, you may want to reassess your ultimate goal(s). The conventional thinking surrounding AML strategy has…

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BSA Officers: How to Mitigate Risks When Hiring a Staffing Firm

By AML RightSource | August 16, 2016

The demand for AML/BSA personnel is higher than ever before. And while demand is at an all-time high, the supply of smart, well-trained people is deficient. This simple issue is crippling banks’ ability to stay current with their day-to-day operations. When demand is high and supply is low, banks typically go outside their institution and look for AML/BSA contractors. However, BSA Officers at every institution understand that contract resources come with significant risks. Despite a…

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Fail Like Lincoln – A Key to Career Success

By Frank Ewing | April 25, 2016

Abraham Lincoln is rarely associated with failure. But as history tells us, Lincoln was a failed businessman long before he was our sixteenth president. In his early twenties, Lincoln partnered with a gentleman named William Berry and purchased a general store (tavern) in New Salem, Illinois. As the story goes, Berry was a drunkard and Lincoln, for his part, was a teetotaler, often preoccupied with odd jobs and laying the foundation for a congressional run.…

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A Dating Guide for Vendor Due Diligence

By Frank Ewing | March 23, 2016

If you’ve ever had a relationship fade out after a few dates, then odds are you already know what it’s like to have a failed vendor relationship.   At first, you wonder how you could have been so wrong. But after some quiet reflection, you realize that maybe, just maybe, your initial screening process was not as strong as you once thought. As time goes on, you realize the warning signs were present from the…

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