byLowers & Associates | August 25, 2015

Firms must comply with the Bank Secrecy Act and its implementing regulations (“AML rules”). – Financial Industry Regulatory Authority The Bank Secrecy Act (BSA) and all the related laws that have been passed since the BSA began in 1970, aim…

byLowers & Associates | July 21, 2015

Both the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) mandate that covered financial entities—and this includes all banking institutions, virtually all money service businesses, and many cash-intensive non-bank businesses—establish an Anti Money Laundering…

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…

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 | 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…