Focus on EB-5 and EB-2 Visas Financial institutions are charged with mitigating the risks of products, services, and customers, and there are many risks presented in each area. For customer risk, one area that is often overlooked is the type … Read More
According to the Federal Bureau of Investigation’s Internet Crime Complaint Center (IC3) 2022 Annual Report, Americans were exposed to approximately $281 million of online shopping and non-delivery scams last year. Many of these scams took place during the holiday season. … Read More
Is your financial institution doing what it can and should to identify and mitigate sex trafficking money laundering risks? Are your risk assessment and transaction monitoring models up to date with emerging trafficking risks and trends? The rise of cryptocurrencies … Read More
In 2004 the FFIEC quietly and subtly shifted the BSA examination paradigm with the publication of the Bank Secrecy Act / Anti-Money Laundering Examination Manual (“the Manual”). The Manual introduced to examiners the concept of determining an institution’s money laundering, … Read More
Background If you have been in banking before 2001, you know that BSA compliance was much simpler and not as burdensome as it is today. When it comes to the “Bank Secrecy Act”, it is important to remember there isn’t … Read More
Warren Buffett once said, “When people tell me they’ve learned from experience, I tell them the trick is to learn from other people’s experience.” This is true in many areas of life, especially when it comes to BSA Consent Orders. … Read More
Introduction The heart and soul of your program is your BSA (Bank Secret Act)/AML This article will define what an AML model validation is and it’s importance. We will also delve into our top ten findings of AML … Read More
Human trafficking is in the news more and more. When it is mentioned, many have a picture in their minds of Asian women working in nail salons. However, this stereotyping of human trafficking is deadly as it blinds people to … Read More
Every year we conduct surveys on important anti-money laundering (AML) topics. A recent survey focused on the topic of Marijuana Related Businesses (MRBs). While marijuana remains illegal on the federal level, more states have begun legalizing both adult and recreational … Read More
A Brief Summary Oddly, despite its significance in the BSA/AML/CFT/OFAC Compliance universe, the BSA Risk Assessment has no statutory requirement even though it is the foundation of any Compliance Program. As compliance professionals, we construct our transaction monitoring systems, OFAC … Read More
This is one of those questions that keep OFAC Officers up at night. Due to the complexity of the OFAC sanctions and the scope of application, it is a challenge to create a robust program and think of everything. However, with the potential of fines with even one violation, and the … Read More