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
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
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
Shortly after the 4th AML Directive took final effect and prior to the 5th AML Directive final compliance date (3 January 2020), the European Parliament passed Directive 2018/1673 – the 6th AML Directive. AMLD6 has a compliance date of 3 … Read More
There are very few, if any, areas of the world, let alone our country, that aren’t watching an unprecedented situation unfold in front of our very own eyes. Confirmed cases of COVID-19, also known as the Novel Coronavirus, have been … Read More
What It Is The general “rule of thumb” in the AML world is that for every method that the financial industry initiates to detect and deter money laundering, the launderers devise a new way around it. We all play by … Read More
On June 30, 2016, the New York State Department of Financial Services (“NYS DFS”) issued the final version Rule 504, “Banking Division Transaction Monitoring and Filtering Program Requirements and Certifications.” The Rule takes effect on January 1, 2017, with the … 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
Overview Many Financial Institutions have installed market-tested BSA/AML Transaction Monitoring Systems to fulfill the requirement to seek out and report on patterns of suspected money laundering and terrorist financing. At the heart of the monitoring activity lies the process of … Read More