byLowers & Associates | July 17, 2015

One of the hottest—and hardest—topics in BSA/AML compliance is managing the risks due to third parties. Regulatory agencies including FinCEN, OFAC, and others have expanded the definition of “third party” to include any business relationship between a financial entity…

byLowers & Associates | July 15, 2015

One of the most important components of BSA/AML compliance is a Customer Identification Program (CIP). After all, money laundering is done by people who do not want to be discovered, and most of them pose as legitimate customers. The…

byLowers & Associates | July 07, 2015

The United States imposes sanctions against foreign governments, individuals, and organizations to achieve specific foreign policy objectives, either unilaterally or as part of a coalition. Since these sanctions have the force of law, they prohibit or restrain certain actions…

byLowers & Associates | June 18, 2015

By their very nature, money launderers will go to great lengths to cover their tracks. In the process, they use the normal activities of legitimate businesses like banks, credit unions, money service businesses, and other financial services organizations to…

byLowers & Associates | June 03, 2015

Like every other important function in a financial entity, a BSA/AML compliance program cannot be expected to operate on autopilot. Managers and employees have to be aware of their responsibilities in the compliance program, and contribute actively as needed….