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Casinos: Responding to New and Evolving Money Laundering Risks
Throughout history, people have engaged in games of chance for entertainment or financial gain. Games of chance are, at their core, based on mathematics and probability. A roll of the dice or spin of the wheel, in conjunction with a set of rules, makes it possible to predict and calculate the likelihood of all possible outcomes.
The Importance of Collaboration in CSE Investigation
Child sexual exploitation (CSE), child sexual abuse materials (CSAM) and child sex trafficking (CST) are serious crimes that adversely impact children being coerced or manipulated into engaging in sexual activity for financial gain. The ACAMS Today Back-to-the-Basics article, “Beyond The Headlines—A Real Look at Trends in CSAM and CST,”1 introduces and delves deeper into this topic and provides a classification for these heinous crimes.
What Are the Sunday Scaries?
“Set peace of mind as your highest goal and organize your entire life around it.” Brian Tracy1 The term “Sunday Scaries,” sometimes referred to as the Sunday Blues, is believed to have been coined in or around 2009. There is some debate regarding who created the term. Some say it was a person who would eventually become a TikTok influencer.
Previously Featured
Casinos: Responding to New and Evolving Money Laundering Risks
Throughout history, people have engaged in games of chance for entertainment or financial gain. Games of chance are, at their core, based on mathematics and probability. A roll of the dice or spin of the wheel, in conjunction with a set of rules, makes it possible to predict and calculate the likelihood of all possible outcomes.
The Importance of Collaboration in CSE Investigation
Child sexual exploitation (CSE), child sexual abuse materials (CSAM) and child sex trafficking (CST) are serious crimes that adversely impact children being coerced or manipulated into engaging in sexual activity for financial gain. The ACAMS Today Back-to-the-Basics article, “Beyond The Headlines—A Real Look at Trends in CSAM and CST,”1 introduces and delves deeper into this topic and provides a classification for these heinous crimes.
What Are the Sunday Scaries?
“Set peace of mind as your highest goal and organize your entire life around it.” Brian Tracy1 The term “Sunday Scaries,” sometimes referred to as the Sunday Blues, is believed to have been coined in or around 2009. There is some debate regarding who created the term. Some say it was a person who would eventually become a TikTok influencer.
Lessons Custodians Can Learn From Traditional Correspondent Banking
Custodians, which are financial institutions that provide the safekeeping and servicing of investor assets including stocks, bonds and other assets, are exposed to some serious money laundering and financial crime risks. The Financial Crimes Enforcement Network’s (FinCEN) unprecedented enforcement action against a trust and custody firm is a perfect example of that risk and the possible consequences.
Four Questions: A Look at the State of Ransomware, Sanctions and Other Global Issues
Sam Cousins is a senior associate at ACAMS, where his work includes supporting public-private partnerships and strengthening ACAMS’ thought leadership pillar through the development of content on sanctions and risk, particularly the Sanctions Masterclass program and Global Monthly Update. Cousins’ work also focuses on countering ransomware financing, which includes enhancing industry awareness of the anti-financial crime risks associated with ransomware attacks and supporting the mitigation of those risks through policies,
Making the World Safe for DeFi, With Seoyoung Kim
In this “Financial Crime Matters” episode, Kieran Beer talks with Seoyoung Kim about the promise and possible perils of decentralized finance. Kim is associate professor of Finance and department chair at Santa Clara University. They discuss the recent implosion of several cryptocurrency exchanges and stablecoin minters and the great legal and judicial debate now raging over the regulation of digital assets.
Ask the AFC Guru: Sanjeev Menon—Staffing Solutions
Anti-financial crime (AFC) guru Sanjeev Menon, managing director of Madison Davis’s Legal and Compliance Practice Area, specializes in executive recruitment and provides staffing and workforce solutions to compliance and anti-financial crime (AFC) clients. Menon, who is an ASA Certified Staffing Professional and holds a Society for Human Resource Management-Certified Professional designation, is here to answer your top AFC staffing questions.
Fines for AML Compliance Failures
Fines to banks for anti-money laundering (AML) compliance flaws can occur due to various reasons. AML regulations are put in place to prevent financial institutions (FIs) from being used for illicit activities such as money laundering and terrorist financing. When banks fail to meet the requirements and demonstrate flaws in their AML compliance, regulatory authorities may impose fines as a form of punishment.
Doris Birmingham: Evolving with BSA
Doris Birmingham is the administrative officer, senior Bank Secrecy Act (BSA) analyst at American National Bank of Texas (ANBTX). Previously, Birmingham was a senior auditor with direct reports and specialized in retail/consumer banking and compliance audits, including BSA, the Sarbanes Oxley Act (SOX), the Privacy Act and the USA PATRIOT Act. She has a proven ability to communicate and build strong relationships throughout the banking network,
Beyond the Headlines—Sextortion
Editor’s note: This article is the second of a three-part series on child sexual abuse material (CSAM) and child sex trafficking (CST). The first part is available here. ***Disclaimer/trigger warning: This article discusses sexual offenses committed against children. Reader discretion is advised. What is sextortion? Sextortion is a form of online extortion that involves the threat of distributing intimate or sexually explicit images or videos of a victim unless they comply with the demands of the blackmailer.
Incorporating FinCEN’s National Priorities Into Risk Assessments
The article titled “FinCEN’s AML and Terrorist Financing Priorities: An Introduction,” featured in the June-August 2022 edition of ACAMS Today, shared general thoughts, basic definitions and practical examples on each of the national anti-money laundering (AML) and counter-terrorist financing (CTF) priorities
The article titled “FinCEN’s AML and Terrorist Financing Priorities: An Introduction,” featured in the June-August 2022 edition of ACAMS Today,Parsing the Challenges of Fighting Financial Crime, With Rick Small, Dan Soto and John Byrne
In this episode of “Financial Crime Matters,” Kieran Beer talks with Rick Small, director Financial Crimes Program at Truist, Dan Soto, chief compliance officer at Ally Financial and John Byrne, executive vice president at AML RightSource about what has been achieved in the past 40 years in the fight against financial crime and what challenges lay ahead.
Managing Risk and Compliance in a Volatile World
An unprecedented confluence of crises has transformed the financial crime and risk landscape, turning the screws on the compliance efforts of financial institutions (FIs). Circumstances such as the ongoing Russia-Ukraine conflict, resulting spikes in geopolitical tensions between the West and Russia and China, in addition to a teetering U.S. economy plagued by stubborn inflation, have presented unforeseen challenges to leaders that call for the fortification of compliance controls and crime prevention strategies.
AI in KYC for Community Banks
Know your customer (KYC) is a familiar topic for all banks, regardless of size. Traditionally for community banks, this was one of the easier blanks to fill in. Being local generally meant a community banker knew their customer personally or at least through easily verifiable means. There is a comfort level to an understanding with relative ease of the expected activity and background of new customers onboarded at a community bank in a traditional setting.
Four Questions: Understanding Sanctions Imposed Against Russia
Russia’s invasion of Ukraine and the subsequent sanctions that the U.S., European Union (EU) and other countries imposed against Russia in the wake of this act of aggression have been the focus of worldwide media attention since February 2022.
FinCEN’s Drug Trafficking Organization Activity Policies
The article titled “FinCEN’s AML and Terrorist Financing Priorities: An Introduction,”1 featured in the June-August ‘22 edition of ACAMS Today, shared general thoughts, basic definitions and practical examples on each of the Financial Crimes Enforcement Network’s (FinCEN) national anti-money laundering (AML) priorities. This article, the ninth of the series, will discuss drug trafficking organization (DTO) activity in greater detail.
Your First 30 Days as an AML Compliance Officer
With the rising threat of money laundering and terrorist financing, regulators are more vigilant in preventing financial crimes. To assist the authorities in curbing these crimes, the anti-money laundering (AML) regulations mandate financial institutions, virtual assets service providers (VASPs), and certain nonfinancial businesses and professions to implement an AML/counter-terrorist financing (CTF) framework.
Preparing for Europe’s AMLA and Fighting Financial Crime, with Dutch Central Banker Willem Schudel
In this episode of "Financial Crime Matters," Kieran Beer talks with Willem Schudel, head of department, Financial Crime Supervision (anti-money laundering and terrorist financing) at the Central Bank of the Netherlands, live from The Assembly Europe, ACAMS’ annual conference, held this year in Dublin.
The Potential Perils of Online Gaming
Online video games have become a popular pastime for people of all ages. However, with the evolution of the gaming industry, exposure to financial crimes is rapidly increasing. The rise of virtual economies and the increasing value of in-game items and currencies have made it more appealing for criminals to use microtransactions and loot boxes in video games to launder money.
The Devastating Effects of Fentanyl Trafficking
Fentanyl is a powerful synthetic opioid drug used for analgesic (pain relief) and anesthetic purposes in both human and veterinary medicine, in addition to treating patients with severe or chronic pain. Launched in 1963 by Janssen Pharmaceuticals, founded by Belgian Dr. Paul Janssen, fentanyl is the most widely used anesthetic in the world.
Jonathan Schnatz on the IRS-CI and Countering Sanctions Evasion
“What we’re really seeing is the use of professional enablers, both by oligarchs to continue to hide their assets, and also in the export controls sanctions cases where they’re using shell corporations to hide the true shipment of goods.” In the latest episode of the “Sanctions Space” podcast, Justine Walker is joined by Jonathan Schnatz, special agent and senior analyst at the U.S.
Revolutionizing AFC Through ChatGPT
Integrating ChatGPT into current anti-money laundering (AML) techniques is a novelty and a controversial issue. ChatGPT was created by OpenAI in 2020 and it is a powerful artificial intelligence (AI) model that uses natural language processing to understand and generate human-like responses. ChatGPT may have the potential to revolutionize AML techniques by automating and predicting the detection of suspicious financial activities, thus reducing the risk of financial crimes.
Creating the Next Wave for Fighting Financial Crime, With FINTRAC’s Sarah Paquet
In this episode of “Financial Crime Matters”—a live recording from the ACAMS Assembly in Hollywood, Florida—Kieran Beer talks with Sarah Paquet, director and CEO of the Financial Transaction Reports Analysis Centre (FINTRAC). Paquet discusses FINTRAC’s new role handling sanctions intelligence, managing the revolution in financial technology and the ongoing commitment of the financial intelligence unit (FIU) to expand and further internationalize Canada’s anti-financial crime public-private partnerships.
Maha Khan: Find the Influencer and Change Will Happen
ACAMS Today sat down with Maha Khan, Financial Sector lead with the Finance Against Slavery and Trafficking (FAST) initiative, a project based at United Nations University Centre for Policy Research (UNU-CPR), during the ACAMS 2023 Hollywood Assembly, to discuss the newly updated Fighting Modern Slavery and Human Trafficking (FMS and HT) social impact certificate and its importance.
FinCEN’s Transnational Criminal Organization Activity Policies
The article titled “FinCEN’s AML and Terrorist Financing Priorities: An Introduction,” featured in
Have Sanctions Against Russia Prompted Commodity Laundering?
Sanctions can be effective if they are proportional to the strength of their enforcement and the unity of global efforts. EU sanctions against Russia, its oil and natural gas industry, are not an exception to this rule. Whilst many suggest that sanctions have worked as planned, the surfacing data reveals that much more collective work is needed.
Matt Zweig on the Dynamics of U.S. Congressional Sanctions Policy
"I always like to describe Congress as writing in pen, and the administration as writing in pencil.” In the latest episode of the “Sanctions Space” podcast, Justine Walker is joined by Matt Zweig, Senior Director of Policy at FDD Action.
FinCEN’s Fraud Policies
The article titled “FinCEN’s AML and Terrorist Financing Priorities: An Introduction,” featured in the ACAMS Today 12th Law Enforcement Edition, shared general thoughts, basic definitions, and practical examples on each of the national anti-money laundering (AML) priorities. This article, the sixth of the series, will discuss fraud in greater detail.
Financial Crime Prevention in Small Companies
“Who watches the watchmen?” Often, in a very small company, there is only one person who serves as both the back office and compliance person. And as the person in the hot seat, you know that good systems are critical to prevent deliberate and inadvertent financial crime.
Unpacking Fintech, Regtech and Suptech
The term financial technology (fintech) is many times used interchangeably when referring to regulatory technology (regtech) and supervisory technology (suptech). However, these technological solutions should not be lumped together. Let us unpack the distinct differences. What is Fintech? Fintech includes the provision of financial services using technology. Initially, banks were using technology to support their systems.
Information Sharing: Why Community Banks Should Participate
Section 314 of the USA PATRIOT Act, which was passed back in 2001, is a vital portion of the legislation. Anyone who had been in the anti-money laundering/Bank Secrecy Act (AML/BSA) space prior to 2001 understands how significant this change was to the industry. Section 314 specifically centered around the ability of financial institutions (FIs) and law enforcement (LE) to share information.
The Rising Demand for AML Specialists
The global COVID-19 pandemic had widespread consequences. International lockdowns and subsequent work-from-home mandates created an unprecedented increase in financial crime, leading to a rising demand for anti-money laundering (AML) specialists. This has been primarily driven by continuous changes in technology, where security measures may not have been as stringent as they should have been.
Re-thinking the ‘War on Dirty Money,’ with Tristram Hicks
In this episode of “Financial Crime Matters,” Kieran Beer talks with Tristram Hicks, co-author with Nicholas Gilmour of “The War on Dirty Money,” an examination of the promise and shortcomings of the current costly global effort to combat financial crime.
Digital AML Transformation in Times of War
After almost a decade of military and political conflict, in February 2022, Russian troops invaded Ukraine through its eastern border in what the Kremlin officially denominated a “special military operation.” Among the immediate results were a massive and ever-growing humanitarian crisis (with more than eight million Ukrainian leaving the country, the biggest refugee crisis in Europe since World War II).
Why FIs Should Consider Banking Marijuana Dispensaries
Former Financial Crime Enforcement Network (FinCEN) Director Kenneth Blanco once said, “Banks must be thinking about their crypto exposure. If banks are not thinking about these issues, it will be apparent when examiners visit.” This advice from the former FinCEN director can also be applied to marijuana banking; financial institutions (FIs) cannot ignore the marijuana industry and expect not to be exposed to the risk associated with the industry.
Toms Platacis on the Frontline of Sanctions Implementation
“Unfortunately, I must say that you don’t have to be a criminal mastermind to come up with a sanctions evasion or circumvention scheme… most of the time, they’re not very sophisticated.” In the latest episode of the “Sanctions Space” podcast, Justine Walker is joined by Toms Platacis, acting head of Latvia’s Financial Intelligence Unit.
Insider Fraud and Employee Monitoring: Learn from Others’ Mistakes
When thinking of employees who have reached managerial roles or work in loss prevention, the last attribute that comes to mind is untrustworthy. However, that is exactly what they were in 2022 at Amazon. These roles naturally convey trust, which can lead to unquestioned agreement and unearned respect.
Keeping Up with the Financial Action Task Force and Beyond, with David Lewis
In this episode of “Financial Crime Matters,” Kieran Beer talks with David Lewis, executive secretary of the Financial Action Task Force (FATF) from 2015 to 2022, about the FATF’s recent plenary that gray listed South Africa and Nigeria, formally suspended Russia from membership, and criticized governments throughout the world for lax oversight of cryptocurrency businesses.
The Big Impacts of Small, In-House BMAs: A Case Study in the Fight Against Corruption
Faced with the challenges imposed by COVID-19 and global economic downturns, what will differentiate strong businesses from weak ones going forward will be their ability to think ahead, adapt and innovate. Fighting corruption and other financial crimes continues to be a huge operational burden and a major pain point for many governments and private institutions, particularly when it comes to investigating and adjudicating underlying criminal activity.
The Great Divide: Getting Convergence Right This Time
As the world becomes increasingly interconnected and digital, so too has the threat of financial crime. Traditionally, siloed methods of combating financial crime, such as anti-money laundering (AML) and fraud detection, must adapt to the changing landscape and find ways to effectively mitigate the risks posed by increasingly sophisticated cybercriminals.
Trade Finance Risk and Controls
Trade finance is described as the provision of finance and services by financial institutions (FIs) for the movement of goods and services between two points, either within a country or across borders. There are multiple methods by which an FI can participate in the financing of product movement. The type of trade finance transaction and the role the FI plays in the transaction is the starting point for determining the risk of the transaction to the FI.
The BSA Tractor
You may have read it in magazines or seen the news or videos of some altruistic country sending modern tractors to aid farmers in developing nations. It seems surprising when they return later to find all the tractors in disrepair, with some now even being pulled by teams of horses. Some reactions blame the farmers for either ignorance or ungratefulness.
FinCEN’s Cybercrime and Cybersecurity Policies
The article titled “FinCEN’s AML and Terrorist Financing Priorities: An Introduction,” featured in the ACAMS Today 12th Law Enforcement Edition, shared general thoughts, basic definitions and practical examples on each of the national anti-money laundering (AML) priorities. This article, the fourth of the series, will discuss cybercrime and relevant cybersecurity and virtual currency considerations in greater detail.
How Britain Became Butler to the World’s Financial Criminals, with Oliver Bullough
In this episode of “Financial Crime Matters,” Kieran Beer talks with Oliver Bullough, award-winning reporter for The Guardian, about his latest book, Butler to the World: How Britain Became the Servant of Tycoons, Tax Dodgers, Kleptocrats and Criminals.
Dissecting the Mafia: Sicily’s Cosa Nostra
For the past 100 years, the mafia’s brutal and lawless presence has influenced everything from pop culture to history, extending beyond Italy’s borders to impact crime around the world. The word mafia is used as an informal term for four major groups: Calabria’s ‘Ndrangheta, Campania’s Camorra, Puglia’s Sacra Corona Unita and the most influential of the groups, Sicily’s Cosa Nostra, or the Sicilian Mafia.
Fighting the Online Exploitation of Children, With Jonathan Dupont and Tiffany Polyak
In this episode of “Financial Crime Matters,” Kieran Beer talks with Jonathan Dupont, a financial intelligence investigator for Western Union, and Tiffany Polyak, anti-financial crime (AFC) associate at ACAMS, about the growth in online sexual exploitation of children and the related rise in child sexual abuse materials on the internet.
Human Trafficking: Detection and Investigations
The first part of this series, “Human Trafficking: Persona-based Typologies and Methodology,” re-emphasized the scale of the human trafficking (HT) problem and the key investigation challenges to tackle, including the need to reconsider the current HT detection and investigation approach.
Justyna Gudzowska and Dan Tannebaum on Looking Ahead to 2023
“As we look at Ukraine, as we look at these unprecedented sanctions, we really have to close the loopholes that are created by the Wagner Group’s presence in many countries around the world, in particular in Africa.” The “Sanctions Space” podcast is back! Justine Walker is joined by Dan Tannebaum, Atlantic Council, and Justyna Gudzowska, The Sentry.
Dozens of Whistleblowers Have Contacted FinCEN Since December: Sources
More than 50 people have secretly flagged anti-money laundering deficiencies and sanctions evasion to U.S. officials in the month since Congress bolstered a fledgling, federal whistleblower program, two sources with direct knowledge of the matter told ACAMS moneylaundering.com. Click here to read the full article.
The Nexus Between Ransomware, Cryptocurrency and Money Laundering
In May 2021, American motorists across the states of Virginia, Georgia and North Carolina panicked as they scrambled to fill their vehicles at gas stations. The run for fuel was a result of a cyberattack on the Colonial Pipeline, which was forced to shut down its supplies of diesel, petrol and jet. Colonial Pipeline’s operations were disrupted by a ransomware attack perpetrated by Darkside―a criminal gang that demanded a ransom of 75 bitcoin ($4.3 million).
Machine Learning: A Game-Changer in the Fight Against Money Laundering
Financial crime, including money laundering, is an illicit growing industry, and criminals are getting increasingly sophisticated. Financial institutions (FIs) are deeply involved in combating this. In North America alone, they spent a little less than $50 billion on compliance in 2021.
The Importance of Regular Independent AML Audits
The legal and regulatory landscape of the anti-money laundering/counter-terrorist financing (AML/CTF) sector is in constant flux and necessitates a dedicated function to assess the level of compliance and the effectiveness of obliged entities’ policies, procedures, measures and controls regularly.
The Nexus Between Terrorism and Human Trafficking
Editor’s note: This article is the first part of a two-part series on human trafficking and terrorist organizations. Human trafficking (HT) constitutes a serious human rights violation and is one of the most profitable criminal enterprises, attracting both small local groups and international networks.
Effective Compliance Programs Have One Thing in Common
According to the Financial Action Task Force (FATF), financial institutions (FIs) should be required to implement programs against money laundering and terrorist financing. The program should support the development of prevention and mitigation measures that are commensurate to the financial crime risk faced.
Beneficial Owners and Sanctions Against Russia: Compliance in 2023
The ball has dropped, the fireworks have faded, and the new year has arrived with new anti-money laundering rules, sanctions and other compliance-related responsibilities on the near horizon for the global financial services industry. Moneylaundering.com reporters Koos Couvée, Gabriel Vedrenne, Fred Williams and Benjamin Hardy asked regulators, investigators, attorneys, consultants and other sources to share their opinions on what the next 12 months hold in store for anti-financial crime professionals.
Sanctions, Shell Companies and Superyachts: Compliance in 2022
If years were disgruntled spouses, 2022 threw everything at us but the kitchen sink, starting with political turmoil in Britain, a criminal referral against a former U.S. president, uprisings in Iran, a standoff between superpowers near Taiwan and a decoupling of the global economy. Click here to read the full article.
Matt Richardson: Preventing Human Trafficking and Online Exploitation
ACAMS Today spoke with Matt Richardson about anti-human trafficking (HT) efforts and the future of HT, his participation in “Dark Highway” (an HT documentary that is being televised in Canada and the U.S.) and the different methods for maximizing online safety. Richardson is director of Intelligence and Investigations with the Anti-Human Trafficking Intelligence Initiative (ATII).
Human Trafficking: Persona-based Typologies and Methodology
Human trafficking (HT) has been widely researched and discussed in different forums and from different perspectives. Most recently, ACAMS Today’s brilliant three-part series, “Understanding Human Trafficking,” clarified key HT concepts, definitions and business models that are useful for every anti-financial crime (AFC) professional to understand.
The Fraudulent Candidate Phenomenon
I thought I had finished writing articles about the effects of the pandemic on work and the employment market. I discussed working from home, returning to the office, the growth of fintech and the renaissance of digital banking and how the new normal would look. But it is time to speak about one of the most interesting and scandalous byproducts of the COVID-19 pandemic: The fraudulent candidate.
The Nature of Synthetic Identity Fraud
In January 2020, the Federal Bureau of Investigation reported that the fastest-growing financial crime in the U.S. is synthetic identity fraud. Banks and financial institutions (FIs) lost $20 billion in 2020 as a result of synthetic identity fraud.
Small Town Politics, Big Time Thefts
The Front Royal-Warren County area of Virginia is known for its rolling hills and quiet suburbs. Despite its proximity to Washington, D.C., Front Royal remains far removed from the hustle of a larger city. Its citizens are tight-knit and proud of their local community. Thus, the shock felt by the community was palpable when one of their own betrayed them.
Elvis and the Fraud Triangle
In 2022, Warner Brothers released the movie Elvis, which explores the complex and sometimes contentious relationship between the King of Rock and Roll, Elvis Presley, and his longtime manager, Colonel Tom Parker, played by Hollywood icon Tom Hanks.
EU Nations Abandon Bloc’s AML Blacklist, Pitch New Beneficial Ownership Rules
After years of wrangling, the EU’s 27 nations finally binned an autonomous blacklist of jurisdictions Wednesday that present an elevated threat of financial crime, or at least did in the eyes of the European Commission, the bloc’s executive branch. Click here to read the full article.
Fighting the Online Exploitation of Children, With Jonathan Dupont and Tiffany Polyak
In this episode of “Financial Crime Matters,” Kieran Beer talks with Jonathan Dupont, a financial intelligence investigator for Western Union, and Tiffany Polyak, anti-financial crime (AFC) associate at ACAMS, about the growth in online sexual exploitation of children and the related rise in child sexual abuse materials on the internet.
Combating Cybercrime, With Bryan Smith
In this episode of “Financial Crime Matters,” Kieran Beer talks with Bryan Smith, chief of the Federal Bureau of Investigation’s (FBI) Cybercriminal Section and a 20-year bureau veteran, about the growing threat of cybercrime to both individuals and large corporations.
FinCEN Takes Steps Towards Reacquiring, Regulating Old Target: Investment Advisers
Federal officials have revived efforts to impose anti-money laundering rules on investment advisers— the gatekeepers of a market worth more than $110 trillion—to plug a widely acknowledged regulatory gap through which large sums flow into the U.S. with little, if any, oversight. Click here to read the full article.
Cybersecurity: Our Shield Against Escalating Cybercrime
As Cybersecurity Awareness Month comes to an end, it is worth remembering that cybersecurity is necessary because of cybercrime. And cybercrime is flourishing. More criminals than ever are lurking online, ready to exploit any technical or human weakness that offers a way into our data. In fact, October might justly be called Cybercrime Awareness Month. The security protocols that protect us can seem tedious if we forget their purpose.
Danske Bank Anticipates $2.1 Billion in Penalties to Resolve Money-Laundering Scandal
Danske Bank on Thursday disclosed that it anticipates having to pay U.S. and Danish authorities a combined $2.1 billion in penalties to settle allegations that its now-shuttered Estonian affiliate helped criminals launder billions of dollars from 2007 to 2015. Click here to read the full article.
Fighting the Trade-Based AML Epidemic with AI
Trade-based money laundering (TBML) is one of the biggest unknowns in the fight against financial crime. It is a big task to tackle, given the complexity and lack of real transparency in global trade financing. Trade finance involves multiple banks in different territories, and most cross-border shipments involve some form of financing, making customer due diligence processes more difficult when multiple parties are involved.
Green Compliance: Adding Potential Complications to Your KYC Onboarding
“Green” is all the rage right now. Professionals are seeing increasing public discourse around climate change, environment, social and governance (ESG), diversity and inclusion and corporate social responsibility. Governments and regulators are taking note and even proposing guidelines as well as regulations to address the various green initiatives. Investors and the public are increasingly demanding that companies identify climate-related risks in their financial results.
Exposing Financial Crime Down Under With Nathan Lynch
In this episode of “Financial Crime Matters,” Kieran Beer talks with Nathan Lynch, author of “The Lucky Laundry,” an exposé of how Australia became the conduit for billions of dollars in laundered funds from the proceeds of drug trafficking, corruption, the sexual exploitation of children and other crimes.
Seattle Area Cryptocurrency Exchange Undermined US Sanctions Against Iran, Russia
Bittrex, a cryptocurrency platform headquartered in Washington state, will pay more than $29 million in penalties to the Treasury Department after willfully violating U.S. sanctions and the Bank Secrecy Act over a period of several years, federal officials said Tuesday. Click here to read the full article.
Hue Dang: Revamping ACAMS Risk Assessment™
Hue Dang, CAMS-Audit, global head of New Ventures and the senior Asia Pacific (APAC) leader for ACAMS, took time to talk with ACAMS Today to discuss the association’s latest efforts in risk assessments in anti-money laundering (AML)/sanctions/suspicious activities. With New Ventures, Dang is the association’s.
One Down, Two to Go: FinCEN Publishes Final Beneficial Ownership Rule
U.S. officials finalized a rule Thursday crafted to prevent criminals from using legal entities to disguise themselves from financial institutions and transfer funds anonymously, launder their profits into real estate and exercise control over legitimate companies for nefarious purposes. Click here to read the full article.
Information Sharing in Modern Times
In a world where financial crime is no longer an if but a when, and no longer an exception but rather an expectation, financial institutions (FIs) need to use all the tools at their disposal to stop financial crime. FIs in the current environment cannot.
Contextual Risk and Its Impact on AML and Sanctions Programs
The term “contextual risk” is quickly becoming a buzzword in our industry as technology advancements and data expansion continues. And while those items are important for efficiency when it comes to developing a contextual risk baseline for customers, it is important in this process not to lose the critical element of the human touch.
Best Practices for Evolving Your Risk Assessment Process
The quote by Lao Tzu feels appropriate considering the numerous public and non-public regulatory actions, resource constraints and lack of senior management engagement that have plagued anti-money laundering/counter-terrorist financing (AML/CTF) and sanctions programs.
Resume Advice for the AFC Professional
In 2016, an article in ACAMS Today provided information and tips on crafting effective resumes. Fast-forward to 2020, when the rapid spread of the COVID-19 virus resulted in the so-called “great resignation” where, for various reasons, large portions of certain industries quit their jobs, leaving businesses searching for applicants to fill open roles.
Red Hot Careers Worth Considering
The financial services sector, especially in the financial technology (fintech) area, has experienced a wave of layoffs lately. This article will cover six career options that are red hot right now in terms of hiring activity.
Central Bank Digital Currency and What It Means to the AFC Industry
According to the Guinness World Records, the first paper-based currency was developed during China’s Tang Dynasty in the seventh century and later introduced to Europe by explorers such as Marco Polo in the 13th century, as stated by the Foundation for Economic Education.
US Lawmakers, Treasury Clash Over SARs
The Treasury Department’s decision to restrict congressional access to financial intelligence on the basis of protecting confidential information and ongoing investigations has created friction with U.S. lawmakers, who say they require the data to perform their constitutional oversight role. Click here to read the full article.
BSA Policy: The Do’s and Don’ts
Many U.S. financial institutions (FIs)1 are subject to the Currency and Foreign Transactions Reporting Act of 1970, better known as the Bank Secrecy Act (BSA). These FIs are required to incorporate policies, procedures and internal controls reasonably designed to assure compliance with the BSA and its implementing regulations in a BSA/anti-money laundering (AML) compliance program.
Fintechs Seeking ‘Master Accounts’ Must Show AML Controls, Regulator Says
Financial technology-centric platforms, or fintechs, with special-purpose charters must meet essentially the same U.S. regulatory standards, including anti-money laundering requirements, as banks to secure access to the U.S. Federal Reserve’s payment rails, the agency advised. Click here to read the full article.
Proceeds of Crime: The Story of Alex Saab
Alex Nain Saab Moránis is a Colombian businessman who illicitly obtained money from multiple millionaire contracts with the Venezuelan government. Saab was involved in two government-funded programs: Gran Misión Vivienda Venezuela, which was designed to build houses for the poor in Venezuela and Comité Local de Abastecimiento y Producción, “the CLAP program,” for delivering food to low-income families.
US AML Cases Hit Record Low in 2021, Sanctions Enforcement Remained Steady
Amid an overall decline in U.S. regulatory enforcement in every category, federal anti-money laundering actions rose in aggregate value last year but plumbed new depths in terms of volume as sanctions-related cases continued apace. Click here to read the full article.
New York Regulator Discloses First Penalty Against Cryptocurrency Industry
Robinhood cofounders Baiju Bhatt and Vlad Tenev walk in New York City on Thursday, July 29, 2021. Robinhood Crypto was fined $30 million by New York’s DFS on Monday, Aug. 22, 2022, for AML and cybersecurity failures. Click here to read the full article.
Managing Financial Crime Risks in Digital Payments
Payment services were long offered to companies and individuals by banks, but in the last 20 years, dedicated and specialized providers greatly expanded the market. In 2020, global payments revenues reached $1.9 trillion.1 Digital payments mechanisms include credit and debit cards as well as recent payments innovations, such as digital wallets. The shift to digital payments is expected to continue.
Risk and Effects on the Economy Through a Unique Lens
Underground financial markets are avenues that offer a shadow banking system. Billions of transactions pass through these channels daily. Due to the advancement of technology, many criminals use this methodology to facilitate their legal and illegal enterprises by means of underground and/or cyber transactions. Even innocent members of the public can get caught unwittingly in criminal schemes through their use of technology.
FinCEN’s AML and Terrorist Financing Priorities: An Introduction
In 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first set of anti-money laundering (AML) and terrorist financing priorities.
Monaco Targets Key AML Vulnerability: Luxury Yachts
The world’s largest yacht, Russian billionaire Andrey Melnichenko’s Yacht A, appears off the coast of Monaco in June 2018. Monaco extended anti-money laundering rules to luxury yacht sales and charters in February. Click here to read the full article.
Lithuania Plans Tighter Cryptocurrency Laws
Concerns that the “exponential growth” of cryptocurrency exchanges and other virtual asset service providers, or VASPs, in Lithuania could fuel financial crime have prompted officials in the Baltic nation to fast-track legal reforms. Click here to read the full article.
US and UK Officials Target Russian Banks, EU Set to Follow
U.S. officials imposed sanctions on Russia’s two largest lenders, which together hold more than half of the country’s banking assets, and 90 of their foreign subsidiaries on Thursday, hours after Russian forces launched a full-scale attack on Ukraine from three directions. Click here to read the full article.
Britain, EU and US Impose New Sanctions on Russia, Threaten Additional Measures
British, EU and US officials targeted Boris Rotenberg, center, and other Russian oligarchs with sanctions on Tuesday, Feb. 22, 2022, following Russia’s latest invasion of Ukrainian territory. Click here to read the full article.
EXCLUSIVE: Ex-FATF Leader Breaks Silence on Resignation, Claims Group Does Not Spur ‘Meaningful’ AML Reform
The former top official of the Financial Action Task Force said he left the post this month because of a perceived lack of support from the group’s president and frustration with its scant success in spurring fundamental improvements to nations’ efforts against illicit finance. Click here to read the full article.
Cayman Islands: Improving FATF’s AML Compliance Rating
In December 2017, the Cayman Islands went through its Fourth Round Mutual Evaluation, a report that analyzed the level of compliance with international standards on combatting money laundering as well as the financing of terrorism and proliferation. The evaluation was conducted by the Caribbean Financial Action Task Force (CFATF), the regional standard setter of the Financial Action Task Force (FATF).
Metaverse: A Virtual World
The metaverse has been making headlines for the past few months since Facebook announced its rebranding to Meta. However, there is much more to the metaverse than Facebook’s version. The metaverse has actually been around for a few years now, and there is more than one single metaverse. The metaverse itself is a concept in its very early stages of development.
Diego Rosero: Best Practices for MSBs—The First of Its Kind
ACAMS Today chatted with Diego Rosero, one of the authors of the recently published “Best Practices for US Money Services Businesses,” a guide of industry best practices for Money Services Businesses (MSBs) that was seven years in the making, and it is now available for download.
Professor Alexander Rodnyansky and Markiyan Kliuchkovskyi on Strengthening Russia Sanctions and Supporting Ukraine’s Reconstruction
ACAMS was honoured to be joined at our Europe conference by two advisors of the Office of the President of Ukraine—Professor Alexander Rodnyansky and Markiyan Kliuchkovskyi. In the margins of the event, Rodnyansky and Kliuchkovskyi sat down with Justine Walker for this "Sanctions Space" podcast episode—their discussion includes the measures they are looking at to stymie Russia's ability to fund its invasion, the weaponization of global food insecurity by Russia and efforts being explored to use the assets of Russian oligarchs to support the reconstruction of Ukraine.
EU’s AML Agency Would Supervise Cryptocurrency, More Banks Under Latest Plan
EU nations want an impending bloc-wide anti-money laundering regulator to directly supervise all manner of financial institutions, including virtual asset service providers, or VASPs, and monitor at least one bank or other AML-regulated company in each country. Click here to read the full article.
Addressing Bribery and Corruption in Jamaica
Jamaica’s anti-corruption oversight body tabled its annual report in Parliament on July 6, 2021 but still managed to make several recommendations for bolstering its existing legislative framework.
Lora von Ploetz: The New Face of Leadership
ACAMS Today Europe spoke with Lora von Ploetz, head of a Global Financial Crime Unit focusing on mitigating significant financial crime risks, proactive investigations, analytics and technology. She discusses the impact of Russian sanctions, challenges faced by European anti-financial crime (AFC) professionals and how she has been a mentor for women in AFC.
Stay Ahead on AML Compliance by Leveraging Smart Technology
Global efforts to tackle money laundering have just been given a mixed assessment. In April 2022, a report from the Financial Action Task Force (FATF) pointed out that although progress has been made in terms of countries’ compliance with anti-money laundering (AML) rules, many still face significant challenges in taking effective action to mitigate the risks.
Binance Lands €3.3 Million AML Penalty in the Netherlands
The Dutch central bank has fined Binance, the world’s largest cryptocurrency exchange, €3.3 million for handling cryptocurrency-denominated transactions, maintaining digital wallets and offering other financial services in the country without authorization. Click here to read the full article.
EU-wide Rules for Crypto Assets
Crypto assets have given private individuals and groups the ability to access and provide a range of alternative financial services, which fall outside the scope of traditional banking, investments and payment services’ monopolies.
Matis Mäeker: Starting With a Clean Slate
ACAMS Today Europe editorial interviewed Matis Mäeker, head of the Estonian Financial Intelligence Unit (FIU) and a member of the MONEYVAL Bureau. Mäeker has been the evaluator and reviewer of many mutual evaluation reports conducted by MONEYVAL. He is also a member of the Estonian delegation to MONEYVAL and a member of the Heads of FIU of the Egmont Group.
France: The Risks of Outsourcing AML Tasks
In today’s world, decentralisation and globalisation are universally accepted values. Indeed, manufacturing a single pair of jeans involves multiple actors from around the world. “It is estimated that for some [jeans], if you were to put each one of them end to end, the jeans would stretch in kilometres, one and a half times around the world (i.e. 65,000 km!).”
Cullen Commission Blames Ottawa for British Columbia’s Money Laundering Problem
A final report on money laundering in British Columbia published Wednesday, June 16, 2022, spreads the blame for gaps that allowed criminals to move billions of illicit dollars into the province over the past decade. Click here to read the full article.
Harmonisation of the EU AML Framework
Whilst the EU’s anti-money laundering (AML) directive has been in existence since 1991,1 the framework has continued to evolve over the past 30 years. The European Commission has implemented the Financial Action Task Force (FATF) recommendations whilst increasingly adopting its own standards and best practices to meet the political and economic requirements of its 27 member states.
Italy: The Mafia’s Infiltration Into Healthcare
Organised crime has a triple interest in the direct and indirect management of health services in Italy. First, there is interest because of the huge amount of money that revolves around these services, which can guarantee large profits for gangs. Second, investment in health is a fairly easy way to launder the proceeds of illegal activities derived mainly from drug trafficking.
The Evolution of Social Fraud
Fraud can be simply described as the act of deception for personal gain. Acts of deception usually involve victims, either individuals or businesses. In most fraud occurrences, the primary motive and gain is financial. However, data has also become the primary target of fraudulent acts.
Organized Retail Theft Profits Moving Through US Banks
Perpetrators of organized retail crime, or ORCs, use a variety of methods to move and launder their profits, from simple structuring of deposits to complex trade-based and third-party money-laundering schemes, federal investigators and anti-financial crime professionals have found. Click here to read the full article.
Four Questions: Understanding ESG’s Convergence with Fighting Financial Crime
Environmental, social and governance initiatives within financial institutions are a current hot topic for discussion in corporate board rooms and the financial press, with critics writing them off as at best peripheral to the function of corporations and at worst platitudinous distractions from the bottom line.
Understanding and Identifying Sex Trafficking
As we learned in the article Understanding Human Trafficking, in the U.S., sex trafficking is defined as follows: Figure 1: Section 7102 (11) (A) of Title 22 U.S. Code “The recruitment, harboring, transportation, obtaining, patronizing, soliciting, or advertising of a person for a commercial sex act in which the commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such an act has not attained 18 years of age.”
Making Russian Sanctions Stick and Fighting Financial Crime, with Ilze Znotina
In this episode of “Financial Crime Matters,” Kieran Beer talks with Ilze Znotina about the challenges Latvia has faced over the past four years during her tenure as head of the Financial Intelligence Unit (FIU), including enforcing sanctions against Russia following its invasion of Ukraine.
EU Launches Sanctions Busting Crackdown
Bankers, attorneys and other professionals in the European Union who help blacklisted Russian oligarchs evade sanctions would face a higher risk of prosecution under proposed EU legislation. Click here to read the full article.
Megan Lundstrom: Human Trafficking Survivor, Crusader and Game Changer
ACAMS Today had the opportunity to sit down and speak with Megan Lundstrom, an anti-human trafficking subject-matter expert and survivor, consultant, co-founder and CEO at The Avery Center (TAC). Lundstrom discussed what led to the formation of TAC, her personal human trafficking (HT) experience and how financial institutions (FIs) and law enforcement (LE) can partner with HT service centers to help identify red flags and assist victims of HT.
Green Crimes and Sustainable Trade Finance
International trade and trade finance play prominent roles in the economic development of countries. While conventional trade acts as an engine for economic growth and development, sustainable international trade can tackle environmental challenges and prevent the exploitation of natural resources and their criminal use under the garb of international trade.
Understanding the “Freedom Convoy” and the Funding of Extremist Groups, with Jessica Davis
In this episode of “Financial Crime Matters,” Kieran Beer talks with Jessica Davis, a veteran of more than 20 years in defense and intelligence roles in government and the private sector in Canada. They discuss the occupation of Canada’s capitol for three weeks last winter by the so-called “Freedom Convoy,” efforts to support the group via crowdfunding, cryptocurrency and cash, as well as the Canadian government’s successful seizure or freezing of much of that funding.
UK Regulator Highlights Common Compliance Failings by ‘Challenger Banks’
Britain’s financial regulator has warned online lenders and other “challenger banks” to remedy common weaknesses in their customer risk assessments, suspicious-transaction-reporting processes and other aspects of their compliance programs. Click here to read the full article.
AML Controls for Crypto in Europe
There are specific rules in place to regulate and supervise credit institutions and payment service providers across Europe. Banks and other license holders are required to cooperate with their national supervisors, who coordinate their work through the network of national financial supervisors.
Riddle Me This: Why is the Shipment Going?
As discussed in a previous article, “Riddle Me This: Export Controls?”1 governments seek to accomplish national security and foreign policy goals through their control of exports. Understanding the framework and operational implications of export regulations is much like solving a riddle. Merriam-Webster defines riddle as “a mystifying, misleading, or puzzling question posed as a problem to be solved.”
Responsive Approach: Understanding Front Office Needs
In decades past, the banking industry has experienced pivotal changes in the way in which new businesses are acquired and operations conducted. The ever-increasing regulatory demands have created an inflow of risk and compliance specialists that drive the need to implement policies and procedures to protect an organization. As the second line of defense, risk and compliance ensure that the established measures are followed through and provide the necessary guidelines for their implementation.
Shell Companies, Data Hurdles Give Rise to ‘Oscar,’ EU’s Newest Sanctions Project
Europol, the EU’s law enforcement agency, has launched a new initiative to support financial and criminal investigations by the bloc’s 27 nations into parties blacklisted for their ties to or support of Russia’s invasion of Ukraine. Click here to read the full article.
Hunt for Russian Wealth Exposes EU’s Sanctions Shortcomings
Russia’s brutal military offensive against Ukraine has accomplished in a little more than a month what consecutive EU officials and their allies have struggled to do for more than a decade: spurred European nations to get serious about enforcing sanctions. Click here to read the full article.
Preventing Digital Payment Systems Fraud
Digital payment volumes have increased dramatically during the COVID-19 pandemic as more companies sell their products and services through digital channels. These payments have expanded to new areas, such as grocery deliveries, vacation rentals as well as automotive sales and repairs. In addition, more consumers make purchases through mobile apps and digital wallets.
Kaleidoscopic Compliance: How DEI Became an ACAMS Priority
It may be old saw to say it, but it is true: diversity is a strength in anti-financial crime (AFC) compliance. For ACAMS, it is also a priority, thanks to the work headed by Lashvinder Kaur, vice president of global strategic communications, who in 2020 pushed to make improving diversity, equity and inclusion (DEI) a goal for the association and its over 90,000 members across the globe.
Reading the Compliance Job-Board Tarots
Acompliance professional’s day would not be complete without checking the trends in regulation, enforcement and consent orders. Those are the traditional bellwethers of where things are heading and what needs to be done for appropriate and responsive compliance activities. As unnoticed signposts, job boards may be the most revealing yet ignored sources on the state of anti-money laundering (AML) and regulatory compliance.
Canada Pledges More Dollars, New Legislation for AML Overhaul
Canadian officials want to extend anti-money laundering requirements to unregulated mortgage lenders and other new sectors in the years ahead, while also dramatically boosting spending on AML supervision, financial crime investigations and corporate transparency. Click here to read the full article.
Sanctions on Russia: Pay Attention Now, Avoid Emerging Risk Later
The invasion of Ukraine has fundamentally changed the compliance landscape throughout the world. Nations have united in imposing sanctions and export controls. The regulations are changing at warp speed, and the stakes for complying with applicable regulations continues to increase. Risks for doing business with the wrong third party are financial, commercial and reputational in nature and pose ongoing compliance concerns.
Innovation in the Ever-Evolving AFC Industry
Anti-financial crime (AFC) professionals had little idea of how vastly the fight against money laundering, terrorist financing and financial crime would develop domestically and internationally in the years following the 9/11 terrorist attack. Since then, the world has seen a plethora of updates in compliance and legislation, the expansion of financial crimes into the cyber world, the issuance of sanctions and restrictions, among other changes.
Addressing Hunger in Afghanistan, with John Sifton and Patti Gossman
In this episode of “Financial Crime Matters,” Kieran Beer talks with John Sifton, advocacy director, and Patti Gossman, associate Asia director, at Human Rights Watch about the dire humanitarian situation in Afghanistan following the return of the Taliban to power. “One in three families is facing food insecurity” from malnourishment to starvation, says Gossman, adding that the crisis is affecting not only the already impoverished but middle-class and working-class people who are no longer paid for their jobs and have no access to their savings.
FinCEN, Western FIUs Target Russian Finances
The U.S. financial intelligence unit outlined plans Wednesday to boost exchanges of data on illicit transfers linked to Russia with the FIUs of Canada, the U.K. and seven other countries, weeks after the Kremlin triggered unprecedented international sanctions by invading Ukraine. Click here to read the full article.
Ukraine, Russia and Belarus Sanctions Update
Historically, the U.S. government has taken more linear, explicitly restricted approaches to sanctions by naming known individuals, companies, vessels or underlying industries within countries subject to sanctions. Due to the Russian invasion of Ukraine, there are many unknown actors and companies, in addition to the known restricted and named parties. Therefore, the sanction restrictions become more nuanced and call for the human element to research underlying parties to determine if they are indeed restricted.
Delicia Speller: Breaking the Bias through Subject Matter Expertise
ACAMS Today caught up with Supervisory Special Agent (SSA) Delicia Speller, a 13-year FBI veteran, for International Women’s Day 2022. She currently serves as a program manager at the FBI headquarters’ (FBIHQ) Criminal Investigative Division (CID), Balkan Eurasian La Cosa Nostra Organized Crime Unit overseeing all FBI Eurasian organized crime investigations.
Combating International Wildlife Trafficking and Other Environmental Crimes, With Olivia Swaak-Goldman
In this episode of "Financial Crime Matters," Kieran Beer talks with Olivia Swaak-Goldman, executive director of the Wildlife Justice Commission (WJC), about the Hague-based organization’s efforts to stop the illegal wildlife trade and other forms of environmental exploitation, currently the fourth largest source of funds for transnational criminal organizations.
Europe and the Illegal Wildlife Trade: Where Are We Now?
An elephant is poached every 30 minutes. An African rhino dies for its horn every eight hours. One in every five fish is caught illegally. In some African and South American countries, 50% to 90% of the wood harvested is illegally traded.
Collaboration: The Key Theme for the AMLA
Requirements of the Anti-Money Laundering Act of 20201 (AMLA) and other legislation will result in a dynamic change in anti-money laundering (AML) programs and subsequent controls. While most of the AMLA statutory requirements have not been finalized, Bank Secrecy Act (BSA) officers should be assessing the impact of the upcoming changes on their programs.
Anticipating the Scope of Possible Russian Sanctions, With Justine Walker
n this episode, Kieran Beer talks with colleague Dr. Justine Walker, global head of Sanctions, Compliance and Risk at ACAMS. They discuss the likely shape of sanctions against Russia, should it invade Ukraine.
BitMEX’s Billionaire Founder Sues to Obtain SARs Filed on Him
A former cryptocurrency executive charged with money laundering in the U.S. has petitioned a U.K. court to compel Wise, a local e-money provider, to give him access to three suspicious activity reports the company filed on him in Britain, and any personal data it collected. Click here to read the full article.
The Continuing Rise of Financial Penalties
The ninth annual Anti-Money Laundering and Counter-Terrorist Financing Supervision Report 2019-201 issued by HM Treasury in the UK highlights notable changes in supervisory activity and fines that supervisors have issued. Civil penalties continue to rise year on year as the Financial Conduct Authority (FCA) exercises its power to curb breaches of money laundering regulations across financial institutions.
Imagining a Better Web3 World That Protects Human Trafficking Victims, With Anjana Rajan
In this episode, Kieran Beer talks with Anjana Rajan, chief technology officer for Polaris about the work the nonprofit does to fight human trafficking, including having helped more than 30,000 survivors via its national hotline. In looking ahead, Rajan talks about the need to recreate the internet to end its use by the powerful to exploit the vulnerable, a reality made only worse by the accelerated digitalization of life in the wake of COVID-19.
SAR Foundations
From 1986 to 1996, U.S. financial institutions (FIs)1 subject to the Currency and Foreign Transactions Reporting Act of 1970, better known as the Bank Secrecy Act (BSA), were required to file a Criminal Referral Form (CRF). Where and when applicable, depending on the requirements during that time, FIs filed multiple CRFs with their U.S.
Central Bank Digital Currency Launched with AML Controls in Place
PwC published the first edition of its “PwC CBDC global index,”1 in which it analyzes the development of central bank digital currencies (CBDCs) as countries around the world race to develop their own digital currency for retail and interbank CBDC. This report ranked the Bahamas as the first in central banks’ retail digital currency project maturity.
Community Bank and Cryptocurrency Customers
Bitcoin hit an all-time high. Coinbase went public. Dogecoin has gone to the moon! These were just some of the cryptocurrency headlines flooding our news feeds earlier this year. According to Coinbase’s website, they have 73 million verified users in over 100 countries as of October 2021. It is safe to say that cryptocurrencies are now mainstream.
Acts, Action Plans and Penalties: AML in 2021
If 2020 somehow failed to darken your doorstep, enter 2021, which began with a violent insurrection at the U.S. Capitol and deadly winter storm in Texas; witnessed the Taliban’s return to power and democratic norms continue to fray across the world; and saw casualties mount and supply chains buckle amid a resurgent global pandemic. Click here to read the full article.
September 11: The 20-Year Journey
Certain events are etched in our minds forever. For those of us who were working in the public or private sector on September 11, 2001, the attacks against the U.S. by al-Qaeda (al-Qaida) were clearly one of those historic moments that remain embedded in our minds.
Reflections of 9/11
This year marks the 20-year anniversary of the worst terrorist attack on U.S. soil. We all remember where we were when we heard the news. I was living in the Rocky Mountains and had just jumped into my car to head to work. I had the radio on and heard that a plane crashed into the Twin Towers.
Twenty Years Later: What We Lost, What We Gained
Most of us can vividly recall where we were 20 years ago on September 11, 2001. At 8:46 a.m., the North Tower of the World Trade Center was struck by what many initially assumed was a small off-course plane. But when the South Tower was struck at 9:03 a.m., it became clear that America was under attack.
Fraud and Fear: COVID-19 Scams
In April 2020, German health authorities were baffled when they discovered that 2.4 million euros worth of medical masks disappeared. Ten million masks were apparently ordered from two legitimate companies in Zurich and Hamburg, which in turn contacted a website registered in Spain to procure the masks needed when the delivery failed to arrive.
Preparing Your FI for AI Adoption
Building your own smart-home solution seemed like a cost-effective idea several years ago when off-the-shelf smart-home solutions were not yet widely available. In reality, operating such a solution would require at least an engineering degree and a lot of patience. Early adopters should not have had to build their own smart-home technology with limited knowledge because smart homes were inevitable.
The AMLA Targets Anonymous US Shell Companies, But Can It Halt Illicit Fund Flows Globally?
The U.S. has long had a problem with shell companies, a loophole that has been overlooked in the fabric of its anti-money laundering (AML) regime. The misuse of anonymous shell companies unjustly enriches kleptocrats and criminals, allowing them to dodge taxes, skirt sanctions, as well as hide, move and launder illicit proceeds.
Nonprofits: Know Your Donor’s Asset Origination
When learning about new trends in money laundering from financial crime prevention experts, one usually does not consider the nonprofit sector and the risk of nonprofit organizations (NPOs) in facilitating illicit transactions. Nonprofits are essential to financing the most vulnerable in society; however, they could become a target for sophisticated money laundering schemes due to the lack of know your donor (KYD) policies and the recent growth of complex asset gifting within donor advised funds (DAFs).
The New Whistleblower Program AML Professionals Should Know
The Anti-Money Laundering Act of 2020 (AMLA) is the most significant change to the U.S.’ anti-money laundering (AML) laws in more than a decade. One provision of interest to financial institutions (FIs) and AML professionals is the expansion of the Bank Secrecy Act’s (BSA) whistleblower program.
Fighting Financial Crime in Canada, With Jacqueline Shinfield
In this episode, Kieran Beer talks with Jacqueline Shinfield, partner at Blakes, Cassels & Graydon about the latest legislative and regulatory requirements from Finance Canada and FINTRAC, that are part of the nation’s renewed vigor to fight financial crime.
Project Shadow: AML Investigations Into Online Child Sexual Exploitation
Project Shadow is a public-private partnership designed to combat online child sexual exploitation in all its forms by enhancing methods to detect, report and disrupt associated financial transactions suspected of being connected to money laundering in any and all of its stages (placement, layering and integration). The partnership is co-led by Scotiabank and the Canadian Centre for Child Protection and is supported by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) with participation from major financial institutions and law enforcement agencies in Canada.
The European Anti-Human Trafficking Legal and Policy Framework: The EU’s Strategy Toward the Eradication of Human Trafficking
This article is the third part of a three-part series on the European Anti-Human Trafficking Legal and Policy Framework. This article focuses on the creation of the ‘EU Strategy towards the Eradication of Trafficking in Human Beings 2012-2016’ as a result of Directive 2011/36/EU. In addition, it is an overview of the extensive legal and policy instruments as well as the strategic documents and resources that address human trafficking at the European level.
The Biggest Thing Since the PATRIOT Act
In this episode, Kieran Beer talks to Daniel Stipano, a 30-year veteran of the Office of the Comptroller of the Currency, about the “Anti-Money Laundering Act of 2020,” the most revolutionary piece of anti-financial crime legislation to emerge from Congress since the “USA PATRIOT Act.”
Cybersecurity Requires Rethinking Cybercrime Investigation
Cybersecurity Awareness Month is a good time to take stock of what can be done differently to improve cybersecurity. Since this awareness event began in 2003, the cyberthreat risk has become astronomically higher. Digital assets are even more vulnerable to theft and compromise. Bad actors across the globe present an ever-greater danger, making cybercrime detection and prevention a central security focus.
Hide-and-Seek: Layering Illicit Funds Via Securities Trading in the Market
Picture a chase scene in an action movie: Hounded by the good guy, the bad guy is running between buildings and crossing streets without waiting for red lights. Suddenly, he reaches a market and disappears into the crowd. Similarly, money launderers exploit the financial markets to blend in with their surroundings and evade detection.
Are Regulators Coming for Crypto?
The meteoric rise of cryptocurrency and its attendant community show no signs of slowing. Having started on the fringes of the financial sector, digital currencies are winning over hearts from Main Street to Wall Street. Crypto exchanges are seeing record growth as coins, both new and established, expand exchange accessibility and gain legitimacy. Even long-time crypto skeptic JP Morgan1 is now recommending clients to include crypto in their portfolios.
The AML Implications of the Human Egg Trade
The money laundering process typically involves the furtive introduction of illegitimate funds into the legitimate financial system and the steps taken by bad actors to distance themselves from the illegal sources of these funds. When the crime is understood, the work of anti-money laundering (AML) professionals is often straightforward, but what is their role when it is unclear if the funds are derived from criminal means because laws are ambiguous?
A Primer on the Pandora Papers
The Pandora Papers were released by the International Consortium of Investigative Journalists (ICIJ) on October 3, 2021, and consisted of 11.9 million records, of which over 6 million were paper files. Out of all the prior leaks from the ICIJ, the Pandora Papers is the largest of three, comprised of over 2.9 terabytes of data. This leak also differed from the prior leaks because 14 providers contributed information for the Pandora Papers while only one firm provided the leaked information for the prior two.
Understanding Terror Finance in the 21st Century, With Jessica Davis
In this episode, Kieran talks with Jessica Davis, president of Insight Threat Intelligence and the author of the just released “Illicit Money: Financing Terrorism in the Twenty-First Century.” Davis discusses her comprehensive book, which is based on her study of some 50 terrorist organizations and terror attacks, in the wake of the Taliban’s return to power in Afghanistan and the rise of ideologically motivated violent extremist throughout the world.
Human Trafficking in the Era of COVID-19
As the COVID-19 pandemic continues to wreak havoc on the globe, criminals continue finding new and manipulative ways to exploit the crisis. Human trafficking has continued to evolve, creating a new wave of victims and revictimization of those already exploited.1 In addition, convergence of criminality has notably been on the rise as perpetrators look to diversify their illicit revenues by further coercing their trafficking victims.
Project Shadow: Ending the Online Exploitation of Children
In this episode, Kieran Beer talks with Barry MacKillop, deputy director at The Financial Transactions and Reports Analysis Centre (FINTRAC) and Stuart Davis, Scotiabank’s global head of financial crimes risk management, about “Project Shadow,” a public-private partnership that combats the online sexual exploitation of children in all its forms.
Rebekah Lisgarten: You Can’t Stop What You Can’t See
ACAMS Today Europe interviewed Rebekah Lisgarten, director of operations at STOP THE TRAFFIK, to discuss the organisation’s achievements in combatting human trafficking (HT) and emerging HT trends. STOP THE TRAFFIK is a pioneer in HT prevention that works to unite people from around the world by inspiring, informing, equipping and mobilising communities to know what HT is, how to identify it and how to respond appropriately.
Exam-Ready AML and Sanctions Programs
After 13 years of working in the anti-financial crime (AFC) field for three financial institutions (FIs)—each with a different regulator—in addition to working closely with peers from all types of FIs, it has become evident that the description “one size fits all” does not apply to anti-money laundering (AML) and economic sanctions regulatory exams. Although the federal functional regulators in the U.S.
Case Management: Doing More With Less
The cost of financial crime operations has steadily climbed due to two main factors: increased volume of alerts and the way operational units are managed. Financial crime analysts and investigators are facing increasing pressure each day as the volume of suspicious activity alerts from a multitude of systems requires their review. Unfortunately, the workload is increasing at a rate that is much faster than staffing levels required to complete the work.
Be Heard: Participating In Federal Rulemaking
When it comes to the U.S. regulatory process, one must admire the unique nature of the government and private sector partnership that exists within the federal rulemaking process. My first job out of college was managing and caring for the small but important business library in our small private sector firm in Falls Church, Virginia.
Cryptocurrency Laundering Grows in Sophistication, Expands Beyond Dark Web
In January 2019, Hamas, a U.S.-blacklisted Palestinian organization, reportedly posted a request on an encrypted communications platform for overseas supporters to donate bitcoins to a single digital wallet that the group had opened with Coinbase. Click here to read the full article.
With Congressional Deadlines Looming, FinCEN Charts Path for Ownership Database
U.S. officials on Tuesday published their long-awaited roadmap for building a national database of corporate owners as mandated by the Corporate Transparency Act, or CTA, legislation widely considered the most comprehensive set of anti-money laundering reforms since 2001. Click here to read the full article.
Sanctions Breaches Trigger Mishmash of US Enforcement Actions for Emirati Bank
U.S. federal and state agencies took different approaches Tuesday in reprimanding Mashreq Bank for moving $4 billion through banks in New York on behalf of Sudan until 2014, when the country was still blacklisted as a sponsor of terrorism. Click here to read the full article.
Dutch Lenders Closing, Rejecting Accounts for Conspiracy Groups During Pandemic
Record anti-money laundering penalties, tougher rules and a growing awareness of the threat of financial crime that certain industries present have led banks in the Netherlands to cut ties with thousands of long-term customers in recent years. Click here to read the full article.
SAR Flagged African Kleptocrat’s Scheme to Move Millions
A SAR flagged an attempt by an attorney for Teodorin Obiang, son of Equatorial Guinea’s autocratic president, to funnel millions of dollars to his client’s country in an apparent violation of an agreement with U.S. prosecutors. Click here to read the full article.
Estonia Intensifies Cryptocurrency Crackdown
Once considered one of Europe’s most attractive jurisdictions for cryptocurrency, Estonia in recent months has intensified a regulatory crackdown aimed at dramatically reducing the number of virtual asset services providers, or VASPs, licensed to operate in the country. Click here to read the full article.
Large US Banks Sharing Financial Intelligence Through Private Exchange
At least eight large U.S. banks have formed a private association to jointly investigate alleged financial crimes and networks of suspects whom federal law enforcement officials flag to them through section 314(a) of the Patriot Act, sources told ACAMS moneylaundering.com. Click here to read the full article.
Cryptocurrency Exchange’s SAR Triggered Federal Investigation into Hamas Fundraisers
A suspicious activity report that flagged a Bitcoin fundraising campaign by Palestinian group Hamas became the starting point for an interagency investigation that ended with the seizure of more than $2 million in cryptocurrency, according to a senior law enforcement official. Click here to read the full article.
US Banks, Fintechs Should Consider Flagging Suspicious Activity Jointly: OCC
Banks that maintain relationships with financial technology-centric firms, or fintechs, should jointly file suspicious activity reports on potentially illicit transactions that affect them both, a senior regulator told attendees of an industry conference Monday. Click here to read the full article.
Counterterrorist Financing, Still a Work in Progress 20 Years After 9/11, Now a Lower Priority
In retrospect, the 9/11 hijackers’ expenditures after they arrived in the U.S. in early 2000 until they crashed commercial jets into the World Trade Center, Pentagon and rural Pennsylvania on the morning of Tuesday, Sept. 11, 2001, 20 years ago this Saturday, still appear “unremarkable,” as congressional investigators described afterwards. Click here to read the full article.
As Humanitarian Crisis Grows, UK NGOs Struggle to Send Funds to Afghanistan
U.K. lenders are exercising great caution in processing humanitarian payments to Afghanistan amid a lack of guidance and uncertainty around the composition of the country’s new Taliban-led government and its future relationship with the international community. Click here to read the full article.
EXCLUSIVE: Fall of Afghanistan Finds FBI Without Terrorist Financing Section
The loss of Afghanistan has potentially opened a door for al-Qaida and other blacklisted groups to expand their fundraising networks, and brought the FBI’s closure of its Terrorist Financing Operations Section two years ago into stark relief, sources told ACAMS moneylaundering.com. Click here to read the full article.
Hindsight for the U.S. in 2020
Not only will 2020 go down as one of the most difficult years in world history due to the COVID-19 pandemic, but the approach to anti-financial crime (AFC) was also fundamentally altered. COVID-19 created new and increased opportunities for criminals to engage in money.
AML in Asia Pacific: 2020 in Review
2020 will be remembered as the year the world changed abruptly. In late January, just after the Chinese New Year, the coronavirus pandemic erupted and spread worldwide. Criminals quickly took advantage of the situation by hoarding masks, sanitizers and other consumer products used to fight.
Under Scrutiny on the High Seas
The current regulatory landscape is the most complex the world has ever seen, with regulatory changes in the financial services sector occurring every seven to 12 minutes. With 80% of world trade¹ traveling by sea, it should not come as a surprise that regulators now see maritime transportation as the principal means of moving sanctioned and embargoed goods across the globe.
E-KYC in the Digital Era
Although consumers and businesses are moving their financial activities online, digital onboarding is hampered by regulations, legacy systems and a disjointed approach for applying customer due diligence (CDD) and know your customer (KYC) controls in online or in-app environments. This article looks at how compliance teams can adapt to a digital environment and perform e-KYC—completely digital customer verification.
Adverse Media Screening Needs AI Truly, Desperately and Immediately
This article will not begin with a story that emphasizes how hard adverse media screening (AMS) currently is―the reader is likely well-aware of the difficulty. It will, however, dissect why it is so hard and why artificial intelligence (AI) is the hero for which AMS has been waiting.
The FinCEN Files: Understanding the Story Behind the Story
In this episode, Kieran Beer talks to Mike Hudson and Spencer Woodman, investigative journalists at the International Consortium of Investigative Journalists (ICIJ), about the 16 months of reporting that went into making sense of the FinCEN Files—more than 2,000 leaked SARs linking the world’s biggest banks, Jho Low, Paul Manafort, Russian oligarchs and international crime networks.
Beyond the Five Pillars: Taking a Holistic Approach to AML
In an effort to improve the effectiveness and efficiency of anti-money laundering (AML) programs, the Financial Crimes Enforcement Network (FinCEN) announced in September that it was soliciting comments regarding potential regulatory amendments to the Bank Secrecy Act. This development is a welcome opportunity to improve at the institutional level what is widely viewed as a broken system—not due to lack of effort or commitment but due to systemic shortcomings in how AML is approached.
A Snapshot of 10 Cybersecurity Challenges for Fintech (And How You Can Resolve Them)
Fintech is a word used in modern parlance within the financial industry that refers to the use of technology and innovation for financial services and systems. Over the years, hackers and cybercriminals have taken advantage of rapidly changing technology as they carry out organized attacks on financial institutions (FIs) by leveraging loopholes in outdated technology and human error, costing institutions millions of dollars in losses and reputational risk in the market.
Identifying the Financial Footprints of Human Trafficking
In this episode, Kieran Beer talks to Dr. James Cockayne, head of the Secretariat of Finance Against Slavery and Trafficking (FAST), a year-old United Nations initiative enlisting financial institutions in the fight against human trafficking. Dr. Cockayne talks about how financial institutions can help track and interdict the proceeds of human trafficking, shun investment in businesses that profit from trafficking and help the victims of modern slavery re-enter the global financial system.
AML in Capital Markets: Insider Trading
Securities typologies are often overlooked by anti-money laundering (AML) programs. The issue is compounded by the absence of effective industry solutions, which tend to focus on payment-oriented transaction monitoring. As AML regulators intensify the monitoring requirements for securities, organizations will need to add the requisite subject-matter expertise to their AML arsenals.
Six Best Practices to Enhance Your Bank’s FCC Testing Program
Within the banking industry, compliance testing involves assessing compliance-related processes and/or controls that can determine whether the bank’s compliance program is designed and operating appropriately. The compliance testing function includes activities focused on financial crime compliance (FCC) testing. Often, FCC testing is performed by a dedicated testing team with the goal of ensuring that internal controls are reasonably designed and working as intended to manage financial crime risk.
ACAMS Videocast: John Roth
In this episode, Kieran Beer sits down with John Roth, chief compliance and ethics officer at Bittrex. Roth has 25 years of experience as an anti-money laundering prosecutor and is now working in the cryptocurrency exchange field. Their conversation focuses on defining cryptocurrency, explaining the market for cryptocurrency and the rise of blockchain technology in financial services.
The Future of Investigations
In movies, investigators put the pieces together. With a massive wall of mugshots, maps and post-it notes, they connect the dots using years of honed intuition—and red yarn. It is an analytical process, and it is exciting. In reality, investigators, especially anti-money laundering (AML) investigators, are spending much more time finding the pieces than figuring out how they fit together—nine times as much time, in fact.
Public + Private—The Silver Bullet Against Financial Crime?
In this episode, Kieran Beer interviews Edward Kitt, illicit finance policy lead at the British Embassy in Washington D.C. Kitt talks about U.K.’s public beneficial ownership register, tangible benefits of the public-private partnership group Joint Money Laundering Intelligence Taskforce (JMLIT) and how effective global information sharing might be the answer to solving new and old cases in human trafficking, art and antiquities trafficking, money laundering and more.
Managing the High-Risk Cannabis Industry
The risks associated with banking hemp companies versus hemp-derived cannabidiol (CBD) companies versus marijuana-related businesses (MRBs) all differ tremendously; for each, the risk posed by a deposit account differs greatly from the risk posed by a loan. To understand why, the legal and regulatory status of hemp, CBD and marijuana must first be understood, as well as other factors that could challenge the value of collateral on a loan if the collateral is hemp- or marijuana-related.
Is This AI System For Me?
It has been almost two years since the Understanding AI column debuted on ACAMSToday.org. In that brief span of time, the technology has gone from fringe to fixture in the minds of anti-financial crime professionals. Dedicated artificial intelligence (AI) solutions are now commonplace and almost every other conference session seems to have “machine learning,” “natural language processing” or some other AI term in its title.
The Financial Tools of Statecraft
In this episode, Juan Zarate explains why sanctions should not be treated like a light switch. He also talks about the U.S. withdrawal from the Joint Comprehensive Plan of Action (JCPOA), and why financial tools are at the heart of national security efforts. In addition, Zarate comments on the delicate balance between privacy and transparency.
Fighting Modern Slavery: What the Banking Sector Can Do to Help
Modern slavery, which represents the recruitment, transport, receipt and harboring of people for the purpose of exploiting their labor, affects almost all parts of the world. Globally, it is estimated that there are over 40 million men, women and children in modern day slavery, with about half of that population in Asia alone.
More Than a Resolution
There is an easy formula for figuring out how to make good on all of your resolutions to come: clarity + effort = success. What makes keeping resolutions so difficult is defining what you truly want (clarity) and doing all that is in your power to get what you want (effort). However, nothing is easy about following through with resolutions.
FCC Testing Within the Banking Industry
What is financial crime compliance (FCC) testing? A report by PwC uses the following definition, “Compliance testing can be defined as a periodic, independent and objective assessment of compliance-related processes and/or controls. The aim of compliance testing is to assess whether the elements, processes and controls of the compliance programme are designed appropriately and are operating as designed.”
Old Trick, New Victims: The Rise of Money Mules During the Pandemic
Following the coronavirus outbreak, mandated lockdowns were implemented that led millions of people to stay home. The financial industry has seen less money laundering cases and fines from regulators because COVID-19 completely disrupted the demand of illicit drug trafficking and successive money laundering measures. During these months of lockdown, millions have been left jobless and have consequentially run out of savings.
Gangsters, Whales and Businessmen—Money Laundering in Canada
In this episode, Kieran Beer talks to Sam Cooper, an investigative journalist who has dedicated his career to expose money laundering in British Columbia. Cooper talks about money laundering operations in Canadian casinos, Chinese millionaires smuggling in cash to purchase swathes of Vancouver’s real estate, financial crime typologies, as well as scams and trends during his investigations in recent years.
Crime in Plain Sight―1MDB
In this episode, Kieran Beer talks to Clare Rewcastle Brown about the latest fallout from 1MDB, the scale and scope of the corruption and how banks can do more to detect these crimes in the early stages. Brown first broke the 1MDB scandal in 2015 and has followed and reported on the developments in the Sarawak Report.
Coaches and Mentors
I used to cringe at the term “executive coach.” It conjured up images of retired corporate types, former athletes, academics and consultants who claim to help executives improve their performance in many areas. How could anyone without any financial crime compliance background truly understand me and my situation enough to help me?
The Beef With Cattle Fraud
Everyone knows fraud and money laundering are two sides of the same coin. Fraudsters do what they do for one reason only—the money. Thus, fraud inherently leads to money laundering as conmen deposit, move or withdraw funds from their illicit activities.
AML Model Governance: Bridging the Domain Gap
Financial crime and compliance teams are continuously trying to improve money laundering detection while ensuring better alignment with regulators’ expectations. Areas hindering this success are the perpetual concerns for transparency and the partnership with model governance teams.
Three Ways KYC Defends Crypto Marketplaces From Financial Crime
The crypto space has become popular not only for cryptocurrency enthusiasts but, unfortunately, for cybercriminals and fraudsters as well. Therefore, most crypto exchanges and marketplaces today employ know your customer (KYC) procedures.
Germany Brings Gatekeepers Into AML Framework
Allegations of the real estate market being used for money laundering (ML) and tax evasion have made headlines in the German media. This has resulted in heated political debates across the political spectrum, particularly, debates on the role of intermediaries. Notaries have been accused by various political parties of neglecting their responsibility in the fight against ML in the real estate sector.
Status of the European AML Framework
In an attempt to improve the integrity, stability and sustainability of the European financial markets, legislators are storming ahead with regular revisions of the European Union’s (EU) anti-money laundering (AML) and criminal law framework.
ACAMS Videocast: Tanya C McCartney
In this episode, Kieran Beer sits down with CEO and Executive Director of the Bahamas Financial Services Board, Tanya C. McCartney. The two discuss the evolution of the board since it was first created 21 years ago and the various strategies for compliance professionals facing today’s challenges in the region. Click here to listen to the videocast.
Extraction Attacks: Fraud and Money Laundering in the Cryptocurrency Space
Fraud and money laundering go hand in hand and fraudsters are early adopters of new money laundering opportunities; as participation in the cryptocurrency space gains momentum, so does fraud. This is not surprising as cryptocurrencies (virtual assets) can be lucrative, easily interchangeable and moved while being fairly unregulated in some parts of the world.
Dr. Allan Wright: Solution-Oriented Dialogue
ACAMS Today interviewed Dr. Allan Wright, manager, research department of the Central Bank of the Bahamas, on the Bahamas anti-money laundering/counter-terrorist financing (AML/CTF) deficiencies and the economic advantages of the Caribbean region. Wright worked as a senior economist at the Inter-American Development Bank and spent two years as a researcher at the Center for Monetary Studies in Latin America.
Money Laundering in Real Estate With Maureen Maloney
In this podcast, the final episode of “Financial Crime Matters” Season 1, Kieran Beer and Maureen Maloney unpick why British Columbia is so vulnerable to money laundering, and how authorities might move to stop it. Professor Maureen Maloney led an expert panel investigating money laundering in British Columbia’s real estate sector. Click here to listen to the podcast.
COVID-19 Speaks, AML Must Listen
The anti-money laundering (AML) community was quickly abuzz with the frauds, scams and schemes criminals found to exploit during the COVID-19 crisis. Nearly all sectors, public and private, were quick to adapt their training and awareness programs. While it is natural to feel revulsion and disgust at the scoundrels trying to profit off this misery, do not let that distract you from the positive attributes this virus disruption can potentially provide the AML community.
Your AMLRx for COVID-19: Part One
By now, reality has set in. The world is in this for the long haul, and anti-money laundering (AML) and sanctions professionals have certainly recognized that the work to protect the financial system will be changed forever. Financial institutions’ (FIs) initial SWAT teams have set up temporary infrastructure to weather out the initial storm.
How Well Do You Understand AI?
Every tech wave has a steep learning curve. In the not-too-distant past, understanding what the internet was or how to use email made one a party standout. Now it is impossible to imagine not knowing either. Just as it was with these innovations, artificial intelligence (AI) is having its brief moment of magical novelty, and those few that can talk about it competently can command more than just a watercooler conversation: They can be a real asset to their organizations.
Breaking Into the Field of Compliance
Nowadays, the compliance function is gaining relevance not only within the traditional financial sector, such as financial institutions, asset managers, corporate and trust service providers, but also from non-traditional sectors such as virtual assets service providers, real estate agents, luxury companies, export/import logistics, among others.
Law Enforcement vs. Cybercrime in Manhattan
In this episode, Michael Sachs talks to Kieran Beer about the cutting-edge work that the Manhattan District Attorney’s office is doing to take down cybercrime. From scams involving Michael Jordan sneakers and black market Xanax, to a crypto-armed robbery, Sachs has seen it all.
Smaller Banks, Higher Risks?
All financial institutions (FIs) are potential targets of criminals seeking to wash their ill-gotten revenues from the telltale signs of their illegal origins. In order to use the money, criminals and terrorists need to place it into the financial system, but in such a way that does not leave a clear trail of incriminating evidence for law enforcement to follow.
Candice Huggins: Recognizing Women’s Daily Contributions
For International Women’s Day 2020, ACAMS Today had the pleasure of interviewing Candice Huggins, chief compliance officer at CIBC FirstCaribbean International Bank, about her career, her role as a woman in anti-money laundering (AML), and what she is doing to make an impact in this industry and her community.
Is Money Laundering in Online Gaming Flying Under the Radar?
In the first episode of “Financial Crime Matters” season two, Anton Moiseienko and Kayla Izenman talk to Kieran Beer about their recent report on money laundering in the online gaming world. They explain how third party marketplaces are being used to exchange illicit game currency for fiat currency. Listen to how financial institutions can spot this activity and the current regulatory response.
The Million Dollar Typo: Breaking Down Why Banks Spend on Ineffective Screening Programs
Recent reports shine a glaring light on the urgent need for new solutions that can help compliance teams more effectively identify and mitigate real risks at the same pace of doing business. Despite this ever-present need, banks spend an inordinate amount of time and money reviewing information unrelated to their customers when trying to assess customer risk.
A Practical Approach to PEP Risk Management
Managing risk associated with politically exposed persons (PEPs) is increasingly becoming an area of focus among financial institutions (FIs) around the world. This increase is due not only to changing regulatory requirements, but also to headlines that have cast many organizations in an unfavorable light for banking some PEPs. PEPs can create increased risks and costs if not managed well.
Kleptopia: Tom Burgis on How Dirty Money Is Conquering the World
In this episode, Kieran Beer interviews the award-winning Financial Times Investigations Correspondent, Tom Burgis, about his new book “Kleptopia: How Dirty Money is Conquering the World.” Burgis reveals how private bankers, law firms and intelligence groups help dictators, oligarchs as well as organized crime penetrate democracies and flood the global economy with dirty money.
From Badge to Banker
When police officers start their careers at academies, they are told they are different from day one. As they begin serving their communities, they realize the role makes them stand out and do work most people would not dream of doing. A career in law enforcement (LE) equips officers with immeasurable skillsets and abilities not normally seen in the private sector.
Thinking Outside of Silos
Search and arrest warrants had been obtained for Gerry (not his real name of course). Gerry—who was accused of operating an unlicensed money services business—had few redeeming qualities. He would move money for the devil himself if the price was right. It is highly unlikely that he has ever been accused of being a nice guy.
Musings From Quarantine on the AML/Compliance Industry
Monday through Friday is drastically different now for a large percentage of people both in the U.S. and around the world. More people are under some type of mandated quarantine today than there were people alive in 1940—2.6 billion. Most, if not all, of you are working from home (WFH) as well as practicing social distancing to both slow the spread of and dodge getting sick with COVID-19.
Three Benefits of Converging Fraud and AML
The human mind is wonderful yet rather mysterious. What the mind looks for determines what it is able to see. Researchers who were looking into this phenomenon, known in the field as “inattentional blindness,” presented oncologists with radiology scans.
Sanctions of Our Time: Iran, Venezuela and the Kingpins
In this episode, recorded in February before the scale of the global COVID-19 outbreak, Kieran Beer and Adam Szubin discuss the effectiveness of sanctions on Iran, Venezuela and the Kingpin Act. A sanctions insider for many years, Adam Szubin has a distinguished history of service with the U.S. Treasury, including nine years as the director of Treasury’s Office of Foreign Assets Control (OFAC).
BSA’s Most Wanted
Picture this: It is the morning of a child’s birthday and this child receives a sought-after building block set. The child knows that the blocks, divvied up by phase into separate packages, will combine to make a glorious final product seen advertised on television. Knowing that creating the set will be time-consuming, the child begins to lay out each package strategically in chronological phase order.
2020 UN North Korea Panel of Experts Report: Takeaways for Financial Institutions
Since mid-April, speculations about dire health or even death of North Korea’s leader, Kim Jong Un, intensified. His absence from the public eye for several weeks and reports about Chinese medical doctors traveling to Pyongyang fueled the rumor mill.
Virtual Currencies—Regulation and Terrorist Financing Risks
The rise of bitcoin and other virtual currencies poses new challenges in the fight against money laundering and terrorist financing (ML/TF). With virtual currencies, users can make global payments that are beyond the control of financial regulators and security authorities. In addition, there is a growing risk of terrorist financiers evading state surveillance and tapping into these new sources of funding.
European Regulators’ View on Technology: Innovation, Caution and Tech-Activism
Rumblings at industry roundtables indicate that financial regulators are setting their sights on technology; they are implementing new technology and expect those that they regulate do the same. With the ongoing raft of regulatory messages, guidance, rules and regulation, it can often be hard to establish what the regulators really want to see and what is pure industry speculation.
Considerations for Building an MRA Validation Road Map
Bank regulators issue Matters Requiring Immediate Attention and Matters Requiring Attention or Matters Requiring Board Attention (collectively referred to as MRAs) to financial institutions (FIs) to communicate supervisory concerns—such as a deviation from sound governance, internal controls and risk management principles, and/or noncompliance with laws and regulations—identified through the supervisory cycle.
Stacey Ivie: Promoting the Spirit of the Law
For International Women’s Day 2020, ACAMS Today chatted with Stacey Ivie, detective for the Alexandria Police Department who holds a Special Deputation with the U.S. Marshals Service, to discuss her career in law enforcement. Ivie is currently assigned as a task force officer (TFO) to the Washington Baltimore High Intensity Drug Trafficking Area (HIDTA) Northern Virginia Financial Initiative (NVFI)—a premier suspicious activity report (SAR) review team.
ACAMS Videocast: Rick McDonnell
In this episode, Kieran Beer sits down with Rick McDonnell to discuss some of the new initiatives and focus from the Financial Action Task Force (FATF), including the impact that “digital identities” are having on fraud, credential security, anti-money laundering and privacy. Rick McDonnell is ACAMS’ executive director and former executive secretary of the FATF. Click here to listen to the videocast.
Title Companies: Expanding Regulatory Territory
More anti-money laundering (AML) regulations could reduce regulatory burden for financial institutions if these new regulations are applied to industries that do not have AML requirements, such as title companies. The U.S. does not have the most stringent regulatory environment when compared to peer countries.
ACAMS Videocast: Amr Rashed
In this episode, Kieran Beer sits down with Amr Rashed to discuss the threat that negative perceptions of cryptocurrency have on preventing financial crimes and how financial intelligence units (FIUs) are adjusting rapidly to gain leverage over money laundering networks that are taking advantage of the private nature of cryptocurrency transactions.
The New ACAMS Brand: The Journey
The idea of improving the world while also changing how you interact with it is best articulated by Leo Tolstoy, who famously said: “Everyone thinks of changing the world, but no one thinks of changing themselves.” ACAMS decided it wanted to do both.
Combating Two Evils With the Same Tools
In the midst of uproar and hot-button debates over historical slavery in the U.S., virtually none of the discourse calls attention to the fact that slavery continues around the world in the form of human trafficking. In June 2020, Wilhan Martono was arrested in northern California for allegedly operating a $21 million human trafficking business.
How Fintech Can Counter Terrorism Funding
The rise of the internet and advancement in mobile technology came with lots of new and exciting developments. But one of the most popular uses of technology in the last two decades—apart from being able to travel to Mars and a breakthrough in genetic engineering—is the use of technology for financial activities.
Online Video Games: Regulatory Overview
Money launderers have targeted the cyberworlds of online video games since they first came into existence. Their use of virtual currencies, both convertible and nonconvertible, and the anonymity provided to players has fostered an environment susceptible to criminal activity.
Small Institution Strategies for Outsourcing BSA Audits
Community bankers often ask examiners which internal audit or consulting firms they should use for Bank Secrecy Act/anti-money laundering (BSA/AML) independent testing. However, regulators cannot endorse or recommend products and services.
Iran’s Pension Funds, Sanctions and the Geofinancial War for the Middle East
The urbanity of the regulatory world obscures the financial industry’s geopolitical side. Beneath the boardrooms, behind the conferences and between the lines of regulation lies the reality of the banking industry’s existence as an economic terrain.
Proliferation Financing: What Financial Institutions Should Know and What They Can Do
Is it possible for a company with no website and no stated business purpose in its corporate documents—acting on behalf of a sanctioned North Korean bank—to use the U.S. financial system? Worryingly, the answer is yes. Mingzheng, a Hong-Kong based company, sent and received wires in U.S. dollars on behalf of a foreign trade bank that was involved in Pyongyang’s weapons of mass destruction (WMD) program.
What to Expect When OFAC’s Enforcing
Would it not be super-nice if sanctions compliance came with a neat menu of do’s and don’ts? Well, it kind of does, but it involves participating in a scavenger hunt of sorts on the Office of Foreign Assets Control (OFAC) website.
18 Years After 9/11: Another Watershed in Global Counterterrorism Finance
This week marks the 18th anniversary of the horrible attacks of September 11, 2001. These attacks marked both the high point of the international terror operations planned and directed by al-Qaida and the beginning of the degradation and complete destruction of the physical infrastructure that al-Qaida maintained in Afghanistan.
Can biometric technology prevent money laundering and terrorist financing?
For decades, the world has been plagued by criminal enterprises, such as drugs, human trafficking organizations and terrorism. In the beginning, these bad actors were able to bypass security measures with ease. Over time, the financial sector has been able to curtail some activities, but these successes are usually reactive.
Legal Restitution as a Financial Intelligence Methodology
Victims of a crime, as individuals or as corporate entities, are legally entitled to restitution. The Mandatory Restitution Act of 1996 established procedures for determining the amount of restitution to which a victim may be entitled. Banks are often a victim of a variety of crimes such as automatic clearing house fraud, check kiting, ATM deposit fraud, mobile deposit fraud, quick change artist, bank robbery, etc.
Dynamic Dialogue: The Ops Plan of a Successful Interview
If having the resume is what brings you to the door of opportunity, the next step is the breach. As law enforcement (LE) strive to make a successful entry into the private sector, knowing the “who” may secure the interview but one must be prepared to answer the “why.” Why should a hiring partner invest in a law enforcement officer (LEO) and the LE experience?
Is all crypto created equal?
Cryptocurrency—a word that strikes fear in the heart of many antimoney laundering (AML) compliance professionals. After all, the root derives from the Greek word kryptos, meaning hidden, and the technology has been linked to both notorious criminal marketplaces like the Silk Road and numerous fraudulent pump-and-dump schemes.
Counter-Proliferation with Tom Keatinge
In this episode, Kieran Beer sits down with Tom Keatinge from defense think tank RUSI to talk about weapons of mass destruction. Keatinge gives his top tips for compliance professionals interested in upskilling in the increasingly complex area of counter-proliferation.
A Smorgasbord of Regulations
Blockchain technology offers a wide array of solutions that challenge traditional business models but this innovation needs updated governance policies to balance efficiency and public safety. Blockchain technology can allow for autonomous users to transfer wealth quickly, worldwide, at any time and without any middlemen using its heretofore most successful use case—virtual currencies.
How AI-Driven Social Media Monitoring for AML Works: Part 1
Most have an opinion—or several—about social media. How and why these networks have importance and influence is up for debate. What is not debatable is that social media platforms share useful information and these platforms do have influence. Compromising photos, information leaks and viral memes shared on these spaces can harm (or even seal) the fate of people and organizations.
The Importance of Emotional Intelligence in Your Compliance Officers
In order to dive into the importance of emotional intelligence, it is imperative to understand the concept first. Emotional intelligence really took off in the ‘90s when Daniel Goleman released his best-selling book, Emotional Intelligence: Why It Can Matter More Than IQ.
Should your company worry about PEPs?
The adage, it’s not what you know, it’s who you know, is often used to decry nepotism. However, when it comes to corruption, personal and professional connections can be equally problematic. This is the case with politically exposed persons (PEPs).
Impossible Evidence: Words, Identity and AI
“I don’t have a good feeling. I feel scared,” the voice of a terrified 17-year-old girl pleaded over the phone. “You know the borders are closed right now, so how am I going to get out?
Virtual Assets: Calibrating the Compass of Suspicion
On October 19, 2018, the Financial Action Task Force (FATF) published long-awaited changes to its recommendations and glossary relating to “virtual assets” and “virtual assets service providers;” these changes supplemented the 2015 FATF report, Guidance for a Risk-Based Approach to Virtual Currencies.
2019 U.N. North Korea Panel of Experts Report: Takeaways for Financial Institutions
The United Nations (U.N.) North Korea Panel of Experts report released this month confirms that North Korea continues to evade U.N. sanctions. The implementation of financial sanctions remains one of the main challenges for governments and financial institutions around the world.
Imposter Syndrome—A Different Type of Fraud
The anti-money laundering (AML) and anti-financial crime professions have been growing at an amazing rate. The tragic events on 9/11, improved money laundering technologies, the Great Recession and increased regulatory scrutiny are just a few of the causes leading to implementation of more robust AML controls in financial institutions.
1984—Making the Cash Connection
Years ago, during a transformative time, Apple Computers introduced the Macintosh, which revolutionized the way people interacted and embraced technology. The Space Shuttle Discovery took off on its maiden voyage and over its lifetime gathered more space flight time than any spacecraft to date.
The Regulators Have Spoken: Technology Leads to Effective BSA/AML Compliance
A U.S. Department of the Treasury working group composed of top regulatory agencies has put out a call for Bank Secrecy Act/anti-money laundering (BSA/AML) compliance to become more effective, affordable and sustainable. The group includes the Financial Crimes Enforcement Network (FinCEN), the Federal Reserve Board, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the National Credit Union Administration.
Emerging Financial Crime Threats for 2019
The first quarter of the 21st century is closing in—but for financial crooks, some things never change. Bank robbing, money laundering and even pickpocketing are as popular as ever and many of the old scams have been made much easier, thanks to the internet.
Wildlife Trafficking: The Urgent Challenge for AML Professionals
The pangolin—a creature found largely in Africa—is the most trafficked mammal in the world. This creature looks prehistoric, weighing anywhere from 2-33 kilograms and measuring 30-152 centimeters. It is estimated over 2.7 million pangolins are harvested and trafficked every year.
AML Experts Ring in the New Year
ACAMS Today asked a few anti-money laundering (AML) experts the following question: From one AML professional to another, how do you establish a strong foundation to accomplish your 2019 goals?
Top Reads for the Anti-Financial Crime Professional
As 2018 ends, the world of financial crime prevention is even more complicated and exciting than previous years. We saw numerous events unfold that have led to more regulations and the need for additional training for anti-financial crime professionals.
The Good Robot: How AI Will Impact KYC
Existing—not future/someday/could be—artificial intelligence (AI) technology can help solve KYC’s false positive overload.
Terrorist Financing: Visualizing Funding Flows
There is one constant in terrorism—the requirement for financing. There must be a steady stream of funds from the point of origin to the point of distribution. Whether the funding is required to sustain the operations of an organization or the activities of individual operatives, without money, terrorists are challenged and less likely to succeed.
The Cybersecurity Article to Read Now
Cybersecurity Awareness will help at home, where hands-on experience can be gained by applying cybersecurity principles to protect family—including children and seniors.
Integrating Cyber Incidents Into Your Anti-Money Laundering (AML) Program
Cybersecurity has traditionally been considered outside of the standard anti-money laundering (AML) program and many AML departments lack expertise in this area.
Front-Running the Traditional “Three Stages of Money Laundering”—Cuckoo Mining, the New Parasite on the Block
Whether one is at home or work, on a laptop or desktop, using a smartphone or any connected device (connected to the Internet) that utilizes computing power, cuckoo miners may come to visit or may already be in residence.
The Future of Correspondent Banking: Collaboration, Innovation and Information Sharing
Correspondent banking fosters economic prosperity throughout the world by enabling business and remittance flows between countries.” However, the complexity and cost of operating as a correspondent bank continues to skyrocket.
Ancient Art, Contemporary Crimes:
What You Should Know About Money Laundering and Antiquities
From plundering during the Crusades to Napoleon’s loot of Egypt, antiquities have long been symbols of worldliness and status. In today’s world, antiquities have become go-to investments for art consumers and market speculators.
Your AI Cheat Sheet: Key Concepts in Common Sense Terms
Artificial intelligence (AI) is back, in a big way, and this time around it works. AI is being deployed across industries and in many problem areas.
Are you missing the smoking gun?
As techniques, typologies, schemes and conduits used for money laundering and terrorist financing become more complex, sophisticated and less transparent, the ability to prove an individual(s) is criminally culpable will continue to be a challenge faced by attorneys, law enforcement and criminal investigators throughout the industry.
Real Considerations for Law Enforcement in Seizing Virtual Currency
Myths continue to girdle virtual (crypto) currencies, including that they are anonymous and exclusively used by criminals to purchase items on the darknet or to launder money.
Organ Trafficking: The Unseen Form of Human Trafficking
Organ trafficking, a lucrative global illicit trade, is often a lesser discussed form of human trafficking among anti-human trafficking stakeholders due to its intricate and often stealth nature.
The Importance of Mentorship
Have you ever thought about your legacy? Have you ever consciously ruminated and decided on how you want people to think of you? I am not alluding to everyone’s subconscious desire to be liked; I am touching on something greater and more significant.
Data Completeness and Integrity Leading Practices for AML and Sanctions Screening Model Validations
Demonstrating data completeness and integrity for mission-critical applications is a necessary step for financial services institutions working to address the AML model validation guidelines issued by the OCC and the Federal Reserve Board as OCC 2011-12 and SR 11-7, respectively (the Guidance).
Starting a Career in AML
I spoke to hundreds and thousands of anti-money laundering (AML) and compliance officers, who all had a story to tell about where they were in their career and how they had arrived to that point.
Lawyers, Drugs and Money: AML in Popular Media
Anti-money laundering (AML) professionals should ponder the many places where money laundering appears in television and movies. Real-world case studies based on indictments and press releases can seem dry, but watching and analyzing visual media has entertainment and perhaps even professional development value.
How Artificial Intelligence Can Help Overcome Challenges in Correspondent Banking Relationships
The capacity to send and receive international payments through correspondent banking is critical to the global economy as financial institutions rely on these relationships to move their customers’ money.
An offer you can’t refuse?
Initial Coin Offerings (ICOs) and Initial Token Offerings (ITOs) are recent innovations for companies to raise capital outside of traditional securities markets and funding sources (e.g., venture capital and angel investors).
A Global Review of Sanctioned Countries
The first known use of sanctions dates to 432 BC when General Pericles of Greece imposed sanctions on its neighbor, Megara, in response to the abduction of three women.
NPOs and De-Risking Challenges
Kay Guinane, program manager at Charity and Security Network, discusses the de-risking challenges nonprofit organizations (NPOs) are facing and how best to maintain a banking relationship in this risk environment.
Implementing the Fifth Pillar of BSA: The Role of the Third Line of Defense
After lingering in regulatory limbo for the last four years, the Financial Crimes Enforcement Network (FinCEN) published the new customer due diligence (CDD) beneficial ownership final ruling in 2016, creating the “fifth pillar” of the Bank Secrecy Act (BSA).
Attaining Success: Where do we start?
During an interview or at a party, how would you answer the question: “So, what do you do for a living?” Let us do a thought experiment. If you were at the end of your career and had reached the level of success you always envisioned and dreamed of, what would your life look like?
Providing a Greater Awareness of Human Trafficking
In lieu of Minneapolis hosting Super Bowl LII in the month of February and considering the influx of human trafficking brought by a large sporting event, on January 11, the ACAMS Greater Twin Cities Chapter (GTCC) hosted a learning event to spread human trafficking awareness.
Shedding Light on Human Trafficking
January is National Slavery and Human Trafficking Awareness Month. ACAMS employees and members across the world kicked off the month by spreading awareness about human trafficking through chapter events, open discussions, social media and more.
Financial Crime Outlook for 2018
At the end of 2017, we presented our year-end compliance review and 2018 outlook webinar. During the presentation, Kieran Beer, director of editorial content and ACAMS moneylaundering.com editor-in-chief, asked the panelists to forecast what 2018 might have in store for us.
It Is Not Too Late…
To read the top articles of 2017 and to prepare New Year’s resolutions for 2018. This year has brought to the forefront cybersecurity, terrorist financing, fraud, de-risking and financial inclusion, Fintech, the beneficial ownership requirement, mutual evaluations and lessons learned, the drug epidemic in the U.S. and cryptocurrency.
A Big Thank You to Our Members
Here in the U.S., we celebrate Thanksgiving this week. It is a holiday celebrated with family and friends. It is also a time to engage and reflect on what we are thankful for this year. Here at ACAMS, we are most thankful for our members. Thank you all for what you do for ACAMS and the anti-money laundering (AML)/financial crime prevention community.
Congratulations! ACAMS Chapter of the Year—Northern Ohio Chapter
The ACAMS Northern Ohio Chapter received the prestigious ACAMS Chapter of the Year Award at the 16th Annual AML and Financial Crime Conference held in Las Vegas at the end of September 2017.
Enter the ACAMS Today Cover Contest
The ACAMS Today Cover Contest is now closed. Click here to view the winners. Artist’s Statement: The first cover is colored without “transparency.” The second cover is a scan of the first cover inside of a colored transparency sheet. The “red” flags of suspicious activity are revealed with “transparency.” Get it?
Obtaining a ‘World-Class’ Certification
ACAMS Today had the opportunity to sit down with two graduates of the Advanced Certification program to discuss how it has helped elevate their careers.
The ACAMS Today Annual Conference Edition is Now Live!
We are pleased to announce that the ACAMS Today Annual Conference edition is now online. This edition covers topics ranging from ML in the art market to deconstructing a fraudster.
Danny Glaser: Sanctions and AML
In this segment of the award-winning AML Now, John J. Byrne, anti-money laundering (AML) speaker, writer and subject-matter expert, interviews Danny L. Glaser, principal with the Financial Integrity Network, about the wide use of sanctions, their importance as a national security tool and Glaser’s thoughts about working in the AML field.
The Way Forward: The Financial Sector Addresses the 2018 Implementation of FinCEN’s CDD Final Rule
Throughout the past two years, our members have constantly sought strategy regarding the impending CDD Rule promulgated by the Treasury's Financial Crimes Enforcement Network (FinCEN).
Current World Events: Sanctions and ML
August is usually a quiet time for the anti-money laundering (AML) community, but those of you involved in sanctions and frankly money laundering investigations know that you need to stay focused on current world events.
Leading the AML Community
One of the most important things we do as anti-money laundering (AML) professionals is lead. Whether it is directing our staffs to the agreed upon mission of protecting our institutions and society from abuse through the movement of illicit funds or ensuring that there is enterprise-wide support for the detection and prevention of money laundering, we must collaborate, communicate and coordinate.
A Strong AML Community
As we approach 50,000 members of Your organization, it is a good opportunity to revisit why we Are a community. If you have been in anti-money laundering (AML) for any length of time, I am sure you are both committed to societal improvement and continuing to grow in your profession.
Your Success is Our Success
As we approach the 50,000-member mark and as the U.S. commemorated their Independence Day on July 4, I would like to thank our membership for your continued support toward the association and also for your continuous efforts in your daily professions in combating financial crime.
A Snapshot of ACAMS’ Annual Vegas Conference
We enjoy seeing our members from around the world at our many international conferences throughout the year. At this time, we are preparing for our largest annual conference: ACAMS 16th Annual AML & Financial Crime Conference, which will be held in Las Vegas, NV on September 25-27, 2017.
Global AML Issues in 2017
At this time of turmoil and challenge, you should know that the global ACAMS community stands with all of you on the need to continue our vigilance toward those that use the financial sector to harm us.
First Chapter Leadership Conference
We just returned from the very first ACAMS Chapter Leadership Conference and the energy, ideas and innovations were amazing! Starting in 2010 with only four chapters, we are now approaching 60 and covering the globe.
Partnerships: The Ultimate Goal
I just returned from the 25th Annual WCAML Forum, a unique program created to ensure that law enforcement and the private sector have an opportunity to candidly discuss various financial crime challenges.
AML at the Center of Global Issues
One of the constant themes for anti-money laundering (AML) professionals is that our "industry" (private or public) continues to need to expand our areas of coverage. Today, we need to understand the financial implications or factors associated with human trafficking, elder abuse, terrorism and the many aspects of fraud.
CDD—Are you ready?
Having just returned from our 22nd Annual International AML & Financial Crime Conference, it is clear that the anti-money laundering (AML) professional is challenged as never before, but they are also confident that by unifying we can tackle many disparate issues.
The Hollywood Conference and CDD Forum
As we approach our 22nd Annual AML & Financial Crime Conference this weekend, ACAMS is excited about a number of "add-ons" we have been fortunate to give our attendees. For example, our mobile app, our panel "takeaways," and the ability to place our virtual livestreams on social media during the conference all enable the anti-money laundering (AML) professional to have new content at their proverbial fingertips in real time. We look forward to seeing all of you in Hollywood or online!
Refresh Your AML Knowledge
Where are you in your anti-money laundering (AML) career? Are your recent entrants working on compliance, investigative or analytical work? Are you managing an AML program, advising or auditing such a program? Whatever your role is, it may be time to "refresh" your AML knowledge.
New Look for ACAMS Connection
With this edition, we are very excited to unveil our new design to your ACAMS Connection. The staff has created a view that allows a quick snapshot of our various areas of coverage (e.g., ACAMS Today articles, chapters, blogs and moneylaundering.com articles) as well as "Quick Links" to a number of other products and member benefits.
Challenges AML Professionals Face
AML in 2017 will test all of us. Whether you are in Europe dealing with Brexit, in the U.S. responding to a new administration, or if you do business in either of those regions, the policy divide that we face will undoubtedly impact anti-money laundering (AML), sanctions and many aspects of financial crime.
Join Us at the Hollywood Conference
Are you joining us in Hollywood? Our 22nd Annual AML and Financial Crime Conference reflects the major challenges facing all of us in anti-money laundering and beyond. What are the regulators expecting? We will cover that important question. Financial inclusion on a global scale has never been more of a pressing problem.
A Dialogue on De-Risking
Kieran Beer and I just returned from the Second World Bank/ACAMS Stakeholder Dialogue addressing financial inclusion and so-called "de-risking." Our focus this time was on the extreme difficulties that charities and humanitarian organizations are having on getting access to financial services and the experienced delays in fund transfers that can result in severe harm to those needing assistance from these charities.
AML IN and OUT List for 2017
There is a media tradition in the U.S., and I suspect elsewhere, for an end of the year "list" of what is (or may be) "Out" and what is "In." The following is my attempt at looking toward 2017 with some predictions and some hopes for the new year…
End of the Year Wrap Up
As we close 2016 and what has been an extremely challenging year for the global anti-money laundering (AML) profession, I want to reiterate my thanks to our members for all you do.
Gratitude
As we approach the Thanksgiving holiday here in the U.S., it is time to reflect on what we are thankful for in what has been an extremely challenging year to say the least. By one assessment there have been 1,582 terrorist attacks with close to 14,500 fatalities.
AML Remains Committed
By the time you read this, the U.S. will have been through the most divisive election in many of our lifetimes. To our members outside of the U.S., we realize that some of you have faced challenges in your jurisdictions as well. The only optimistic view I can offer is that the anti-money laundering (AML) community remains connected, engaged and supportive of working together.
Mentors and Supporters of AML Professionals
It has clearly been a tough few years as we have lost a number of anti-money laundering (AML) veterans who worked so hard in our community. We have posted information elsewhere on our site on the most recent passing of a career committed supporter of public-private partnerships—Mike McDonald.
Stay Connected
One of the most challenging aspects of our profession is staying connected with collateral issues. We have covered the global problem of so-called "de-risking" for the past year and while there has been a number of reports and guidance documents attempting to address it, solutions still elude us.
ACAMS’ 2016 Vegas Conference Highlights
It was both exciting and invigorating to see so many anti-money laundering (AML) professionals at our 15th Annual AML & Financial Crime Conference here in Las Vegas. As I have mentioned many times, AML individuals are both generous with their time and expertise and really want to increase support and awareness of all of the aspects of what constitutes AML oversight.
The Financial Response to 9/11
As I write this, we are one day removed from the 15th Anniversary of September 11, 2001. It would be presumptuous of me to think I can articulate what that horrific day should still mean to many of us, but I can opine on the anti-money laundering (AML) community.
A Thank You Goes a Long Way
While we will be announcing the various winners to a number of ACAMS awards prior to the 15th Annual AML & Financial Crime Conference in Las Vegas, I thought it important that the members recognize everyone who has produced success in our ongoing challenges. Take the time to thank someone in law enforcement for what they have done to address the many issues that comprise money laundering.
Working Toward a Common Goal
As the working world slows down (a bit) during August, we should not lose sight of all that remains for the anti-money laundering (AML) profession during the remainder of 2016 and beyond.We have witnessed massive corruption around the globe with countries and organizations such as FIFA only being a few.
A Call for Feedback
Frequent visitors to our website, attendees at our conferences and seminars, and listeners to our webinars, all know that ACAMS is constantly seeking insight, input and recommendations.
Get Involved!
It is hard to believe, but it has been close to 30 years since the passage of the Money Laundering Control Act of 1986—a law that created the anti-money laundering (AML) infrastructure in the U.S. we know today. With all of the continuing challenges facing our community in 2016, I still encourage all of us to think through potential changes to laws, regulations and policies.
Connecting the AML Community
Every so often I like to remind our members to please take advantage of our ability to connect the ACAMS community through the forums we offer and the polling questions that give all of us a current view into issues, themes and challenges.
Actively Making a Global Difference
As anti-money laundering professionals, we are active members of the global society. What we do in sanctions, the countering of terrorist financing, detecting human trafficking and many other areas that touch financial crime, does make a difference and we should be proud of that fact.
De-Risking Challenges
Coming on the heels of the European conference, most of the ACAMS Advisory Board joined Kieran Beer and me last week for a "Stakeholder Dialogue on De-Risking" with the World Bank Group in Washington, D.C.
AML Commitment in Europe
As the second day of our European Conference begins, I remain heartened by the ongoing commitment of anti-money laundering (AML) professionals to aggressively address the wide array of financial crime activities that challenge all of us. Whether it is human trafficking, terrorist financing or cybercrime, the AML sector (private and public) continues to share information, best practices and overall strategies to assist in the joint combating of these attacks against society.
The Long-Awaited CDD Final Rule
We now know that the U.S. Treasury Department has issued the long-awaited Customer Due Diligence (CDD) Final Rule. Our members can find the regulation on our discussion forum and in MLDC.com, and ACAMS will be offering a free webinar on May 13.
Preparations for the Next CAMS Exam
Last week I spent three days with a number of your ACAMS colleagues reviewing hundreds of questions (items in examination parlance) for the next edition of the CAMS examination (it will be the sixth).
The Conference Experience
The last day of the 21st Annual International AML & Financial Crime Conference in Hollywood, Florida is finishing today. The conference hosted over 1,700 attendees from all over the world and from diverse financial industries.
Let Us Expand Our Goals
As we approach the end of March, our thoughts logically begin to focus on the conference season and the opportunity to see peers, colleagues and other anti-money laundering experts. We will continue our efforts to learn from each other and share best practices and other valuable types of information sharing.
How to Benefit from the ACAMS Community
We have encouraged the membership many times to post comments, recommendations and even debates on the Discussion forums. A number of you have taken advantage of this excellent information and learning feature, but it seems as if the time is now ripe to hear from more of you.
Important AML Information
Having just completed our webinar with the American Gaming Association (AGA) on their new report covering the state of anti-money laundering (AML) in that industry, I also noted that AGA was very prescient to make sure the report was completed while the Financial Action Task Force (FATF) mutual evaluation of the U.S. was in progress.
Constantly Moving in an Ever-Challenging AML World
ACAMS members are constantly seeking support for the myriad of regulatory, legal and policy challenges facing them. Whether it is the misplaced attacks in certain areas on compliance officers or the very fair criticism that anti-money laundering (AML) professionals need to continue expanding their knowledge base, we are working toward improving our suite of learning tools.
Growing Challenges
2016 is already moving rapidly for all of us in anti-money laundering (AML)/sanctions/financial crime prevention. In the U.S., our laws and regulations are being evaluated by the Financial Action Task Force and as a reminder, the 259 completed evaluations are available on their website as important due diligence training tools.
Making the Most of Your Membership
We are excited about what 2016 will bring to the ACAMS community. On April 19, 2016, we will be hosting our third ACAMS virtual career fair from 12:00 p.m. to 3:00 p.m. EDT. We hope you will join us for this networking opportunity.
Starting the Year Off Right
Happy New Year to all of our members—we hope everyone has a safe and productive 2016! As we mentioned last month, we want to begin 2016 with a positive tone. Thus, ACAMS is pleased to offer an opportunity to recognize your peers in anti-money laundering (AML) with our new "ACAMS AML Professional of the Month."
Acknowledging the AML Community’s Commitment
As we approach the close of 2015, anti-money laundering (AML) professionals need to recognize it is time to acknowledge that not everyone understands how diligent and committed you are to the goal of detecting, reporting and preventing the movement of illicit funds.
A Special Thank You
As we approach the holiday of Thanksgiving tomorrow in the U.S., I want to reiterate our appreciation for the work of the ACAMS community around the globe in addressing the many anti-money laundering challenges facing all of us. Thank you!
The Importance of Partnerships
At a meeting I attended last week, several things were made clear yet again. Most of us in the anti-money laundering (AML) profession do not seem to appreciate the hard work and commitment of the brave men and women in law enforcement.
Taking Advantage of Valuable Information
Last week, the Financial Action Task Force (FATF) Plenary meeting concluded with a number of "outcomes" that the public and private sectors should review and communicate to anti-money laundering (AML) professionals in financial institutions, agencies and firms.
Personal Liability
I just read yet another article about government prosecutors in the U.S. making clear their intention to "go after" individuals involved in corporate criminal activity. While a common action outside of the U.S., personal liability is relatively new here and presents an opportunity for the anti-money laundering (AML) community.
Conference Takeaways
As we finish day three of the largest anti-money laundering (AML) conference in history, it is important to remind ourselves why this has occurred. First, the expansion of terrorism, human trafficking and overall fraud against the innocent requires a coherent and broad response.
Attaining a Strong Culture of Compliance
Our colleagues at ACAMS moneylaundering.com have been covering the recent pronouncements from the U.S. Department of Justice (DOJ) on their new policy regarding "Individual Accountability for Corporate Wrongdoing."
Evaluating the Conference Experience
As we approach the fall conference season, I want to remind everyone that you only get as much out of the experience as you put in. Here are a few recommendations to enhance the conference and post-program value.
What can the AML community do?
I am sure that by now you have read about the settlement in the Arab Bank case regarding the payment of monies to victims of attacks by Hamas. This is not about the merits of the case or the notion of holding banks responsible for the use of funds to commit horrific acts.
The AML Environment
Last week I had several opportunities to see the broad anti-money laundering (AML)/financial crime environment in action. First, I had the privilege of discussing the AML area of 2015 with a large number of examiners under the Federal Financial Institutions Examination Council (FFIEC) umbrella.
Start Enhancing Your Expertise
My colleague Kieran Beer (MLDC editor) and I spoke to a large bank audit group this week and discussed trends and themes for the rest of 2015 and into 2016. What struck me is both how many issues are challenging the anti-money laundering (AML) professional and is anybody listening?
Celebrating Partnerships
Several of us from the staff were honored to attend the ACAMS NY Chapter's 10th Anniversary Gala last week. It is comforting to see the dedication and commitment of anti-money laundering (AML) professionals from all parts of the community get together and celebrate their ability to partner, share ideas and work with peers.
Building Opportunities to Share Information
A constant challenge for ACAMS is to ensure that we provide opportunity for our members to have access to the most recent guidance, reports and analysis on relevant anti-money laundering (AML) and financial crime information. We do that through ACAMS Today, conferences, the Resource page on our site and the Discussion forums.
Committed to Working Together
As we wrapped up our most successful Canadian conference to date on Tuesday, I am so appreciative of the commitment of the anti-money laundering (AML) community here to work together to deal with all of the many challenges facing the private and public sectors.
Addressing Global AML Challenges
As we approach the 11th Annual ACAMS European AML & Financial Crime Conference this week in London, it is clear that our anti-money laundering (AML) challenges are similar throughout the globe. Whether it is an increase in formal regulatory criticism or the ongoing debate on so-called "de-risking," AML professionals need resources, management support and enterprise-wide commitment to address these issues.
Are you using our resources?
We are all aware of how much anti-money laundering (AML) has changed in the 13 years since ACAMS was created. Being a money laundering prevention expert is no longer limited to simply understanding record keeping and reporting. In 2015, we are all charged with the need to know sanctions, financial crime, corruption, cybersecurity and of course terrorist financing.
How can the ultimate goal be accomplished?
In yet another attempt to engage anti-money laundering (AML) professionals, we have added a new polling question to our website on the challenge of de-risking. I am convinced that all sides to this current debate are talking passed each other.
Start the Conversation Today
With all of the dialogue on so-called "de-risking," I still feel that anti-money laundering (AML) professionals are talking passed each other. Whether it is concern about the impact on "financial inclusion" or the inability of law enforcement to monitor entities whose accounts have been exited, the core reason for the problem is being glossed over—financial institutions deciding to exit because of lack of clarity around managing risk.
A Need for More Effort
As we finish this session of the ACAMS Advanced Certification classes, I continue to be so impressed at the level of anti-money laundering (AML) expertise of the candidates for the CAMS-Audit and CAMS-FCI designations. In addition, these ACAMS members are committed to improving the overall community, whether as financial institution professionals, consultants or government employees.
The AML Journey
As day three of our 20th Annual AML and Financial Crime Conference draws to a close, I continue to be so impressed by the quality and passion of the AML professional.
Conference Takeaways—Just One More Way We Have Improved ACAMS
As ACAMS continues to grow toward 30,000 members worldwide, we have to continue to provide you with outlets for your AML/financial crime needs. In 2015, we take advantage of Twitter, podcasting, web-only articles, robust webinar content and add-ons to our very successful conferences.
The AML Conference Season
After five years here at ACAMS, I may have a tendency to repeat myself (my kids will say that is constant) but as we approach March, it is full-fledged conference season. For the relatively new anti-money laundering (AML) professionals, this may seem rather innocuous, but for those of us that have spent many years trying to stay abreast of new trends and themes, conference season is an opportunity.
What are you doing to stay ahead of the AML curve?
With the myriad of challenges—more sanctions, personal liability, the de-risking "crisis," and the need for relevant training—how do you keep up? If you are in a financial institution, senior management must respect and embrace the notion of a highly trained staff with adequate resources.
The Time for Silence is Over
As discussed during the 5th Annual ACAMS MENA AML & Financial Crime Conference, I believe we face a crossroads as members of the anti-money laundering (AML) community. Organized criminals and terrorists of all kinds continue to haunt society’s desire for a safe and law abiding world.
AML Community: Are you with us?
As we start 2015, there is a lot of work to do. With regulatory penalties, reputational challenges and now personal liability facing anti-money laundering (AML) professionals, we need to not lose sight of our collective mission—attacking the use of financial institutions by criminals, terrorists, cartel members and all who take advantage of society.
The Importance of Staying Current
Closing 2014, it remains important that we stay current with the many and varied ways illicit funds move through the global financial system. ACAMS depends on our members for the necessary insight that we can include in our publications, training and other educational offerings. So please keep it coming!
A Time to Reflect
During the past month I have had several opportunities to discuss with financial institution association members about their anti-money laundering (AML) compliance struggles.
Changing the AML Status Quo
Having just returned from the 5th CAMS-Audit program and the 2nd CAMS-FCI, I am continually impressed at the high levels of professionalism and commitment from our membership. We are honored to have the CAMS certification represented by AML professionals that are leaders in their institutions and with their peers.
What are your views on AML?
Twenty years ago, the U.S. Treasury created (by legislative direction pushed by the private sector) the Bank Secrecy Act Advisory Group (BSAAG). This public-private forum was designed to improve the money laundering laws and regulations in place at the time and to share information on emerging trends in criminal activity based on financial transactions.
A Call for Dialogue
As AML professionals in the private or public sectors, we all share the view that the process for detecting, preventing and reporting financial crime is broken. Not because of a lack of commitment from all sides, but due to confusing priorities, conflicting laws and regulations, and a lack of transparency on many levels.
Greetings from the 13th Annual ACAMS Conference!
We are finishing here in Las Vegas at what has been the largest AML conference in history! While we can take some credit here at ACAMS for listening carefully to our members on topics, speakers and themes, the overarching reason for this unprecedented attendance is the constant raising of the bar regarding AML compliance.
Always Remember
As I write on 9/11, it is important to note why we are in the AML field. The pursuit of terrorists, drug traffickers and other criminals is an honorable profession whether you are in the private or public sector. The horrific acts on that fateful day and the subsequent attacks by the lowlife that inhabit our world can be fought on several fronts.
Work Toward Improving Your Career
When we discuss programming at our webinars, conferences and seminars, we constantly come back to the regulatory refrain that AML professionals need to stay several steps ahead of the criminals.
Maintaining a Good Tone at the Top
We have heard many concerns about personal liability for AML and other compliance officers as a result of several cases pending or completed and reported by our ACAMS moneylaundering.com.
Weighing in on Important Issues
As anti-money laundering (AML) professionals, we have many varied roles and responsibilities. Besides overseeing compliance responses to a continuing series of laws, regulations and guidance, you must watch for changes in obligations based on enforcement actions and regulatory expectations gleaned from speeches and other public comments.