The ACAMS New York Chapter community was enthused to attend the summer learning event "Handling a Government Money Laundering Investigation of Your Institution" on July 13. The program, hosted by Kroll at The Union League Club, was moderated by chapter co-chair Barry Koch and featured board members Meryl Lutsky and David Chenkin. The event saw over 200 attendees.
Lutsky is the 2010 recipient of the ACAMS Professional of the Year award and has been the Chief of both the money laundering unit of the New York State Attorney General's Office and the New York State Crime Proceeds Strike Force since 2004. Chenkin is a partner at Manhattan law firm Zeichner Ellman & Krause LLP.
The two speakers outlined the process by which a financial institution may come under investigation by law enforcement. Lutsky provided the prosecutor's perspective while Chenkin spoke from his experience representing financial institutions.
Lutsky explained the various ways by which her office or other law enforcement agencies may begin an investigation of a financial institution. She cited whistleblowers, regulatory scrutiny and SAR filing data as examples of catalysts. One interesting way in which prosecutors find flaws in anti-money laundering programs is through lack of SAR filing. Lutsky commented that if every major bank is filing regular SARs on a particular hot topic (such as mortgage or lending fraud) and one similar institution is not filing any SARs of this nature, the silence speaks volumes. The lack of filing may cause a prosecutor to have doubts about that institution's processes involving a specific product or service.
Chenkin shared an acronym to live by in regards to these investigations. DNILE stands for "Do Not Ignore Law Enforcement." He spoke about how souring a relationship with law enforcement, whether intentionally or not, can hurt an institution's chances of coming out of an investigation unscathed. Common mistakes include not adhering to the specific terms of a subpoena request or being slow to release information. Lutsky confirmed that cooperating with law enforcement can only help an institution and has, in the past, led to leniency on the part of the prosecutor.
At the conclusion of the July event, chapter co-chair Vasilios Chrisos took time out to thank Koch for over two years of service to the chapter board. The New York Chapter has enjoyed an amazing run under Koch and Chrisos' leadership, having quadrupled its membership and hosted numerous learning and social events including ACAMS' first ever all-day learning event hosted by a chapter. Koch will remain on the New York Chapter board and will be succeeded as co-chair by the board's former communications director, Erika Giovanetti.
The New York Chapter has an interesting and exciting 2011-2012 season planned, including the rollout of several new types of programming. For information regarding membership or recent learning events, please visit the New York Chapter webpage at http://www.acams.org/new-york-chapter/. Please feel free to contact the board at firstname.lastname@example.org.