AML Challenges

Five Tips for the Fifth Pillar

April 25, 2018April 24, 2018 /Leave a comment

The Customer Due Diligence (CDD) Final Rule, issued by the Financial Crimes Enforcement Network in 2016, will take effect on May 11, 2018. The Rule codified many of the existing regulatory expectations already associated with a sound due diligence compliance program and established a fifth...

AML Challenges, March - May 2018

Reputationally Exposed Persons and Corruption Risk

March 20, 2018 /Leave a comment

Most institutions are familiar with politically exposed persons (PEPs), but fewer organizations have formalized policies around a broader risk category of reputationally exposed persons (REPs). REPs may have connections to the political world, government contracts or commercial activity and may be at risk for...

AML Challenges, Exclusive, March - May 2018

Challenges with the CDD Final Rule Compliance

March 20, 2018March 28, 2018 /Leave a comment

“Accept the challenges so that you can feel the exhilaration of victory.” — George S. Patton As the May 11, 2018 compliance date for the Customer Due Diligence (CDD) Final Rule draws near, financial institutions are finding challenges with complying with the Rule’s requirements....

AML Challenges, March - May 2018

Human Trafficking in Native American Communities

January 19, 2018March 16, 2018 /Leave a comment

Since the Presidential Proclamation of 2010, we have annually observed January as National Slavery and Human Trafficking Prevention Month. We also recognize January 11 as National Human Trafficking Awareness Day. Despite all the media attention and many worthy organizations fighting this problem, there are still...

AML Challenges, December 2017 - February 2018, Exclusive, Global Financial Crime Review

Project Protect: An In-Depth Review of the Public-Private Partnership to Combat Human Trafficking in Canada

December 12, 2017January 24, 2018 /Leave a comment

Editor’s note: This article was shared with the Vatican’s Pontifical Academy of Social Sciences (PASS) as a supplement to their Workshop on Assisting Victims of Human Trafficking that took place on November 4-6, 2017, in Vatican City. Ending human trafficking is often regarded as an...

AML Challenges, December 2017 - February 2018

Leveraging Your Community to Survive Beneficial Ownership

December 12, 2017 /Leave a comment

We in the Bank Secrecy Act (BSA) world are accustomed to keeping our noses to the grindstone and getting the job done. From early morning to late in the evening, we read news articles, research suspicious activity and answer questions from staff and customers...

AML Challenges, Europe, September – November 2017

Artfully Done

September 19, 2017September 25, 2017 /Leave a comment

Under the Wave off Kanagawa (Kanagawa oki nami ura), also known as The Great Wave, from the series Thirty-Six Views of Mount Fuji (Fugaku sanjūrokkei) is one of the most recognizable works of Japanese art in the world. This wood block print by the...

AML Challenges, September – November 2017

Cybersecurity: Nation-State Actors, Encrypted Cybercrimes and Man-in-the-Middle Attacks

September 19, 2017September 19, 2017 /Leave a comment

CNN recently reported that the banking industry generally escaped the devastating impact of the global WannaCry ransomware attack. Evidence is mounting steadily that North Korea... Continue Reading

AML Challenges, Exclusive, September – November 2017

Emerging “Market” Trends

September 19, 2017October 26, 2017 /Leave a comment

By now, certain shelf items have been labeled with a stock keeping unit (SKU), been advertised in circulars and placed out on display for resale. With the science of inventory management applied to market commodities for a quick profit, the question is should the abuse...

AML Challenges, June – August 2017

The Human Side of Cyber Risk

June 9, 2017June 9, 2017 /Leave a comment

Spend time with retired four-star General James Jones and you will likely hear his ominous bifurcation of “those companies that have been a target of a cyberattack, and those that will be.” As former U.S. National Security Advisor to the President and Commandant of the...

ACAMS Today

The Magazine for Career-minded Professionals in the Anti-Money Laundering Field

Dennis M. Lormel’s Statement before the U.S. Senate Banking Subcommittee on National Security, International Trade and Finance Hearing

Sluicing Public Data

Final Rule: Achieving Successful Implementation

Assessing Terrorist Financing Through the Lens of the Terrorist Attack Cycle

Whales, Sharks and Flounders: Conceptualizing Real-World Money Laundering