FinCEN’s Alan Cox Foreshadows AML Enforcement Actions in Armored Car Industry Address

By Lowers & Associates,

armored truck

Last month we had the pleasure of sponsoring and attending the third annual Secure Cash and Transport Association (SCTA) conference in Chicago. One of the sessions at the conference was presented by Alan Cox, of the Financial Crimes Enforcement Network (FinCEN). He is the Acting Associate Director of the Liaison Division for FinCEN. In this role, he oversees major activities at FinCEN to combat money laundering, terrorist financing, and other forms of illicit activity.

FinCEN is a bureau of the treasury that writes anti-money laundering rules, anti-terrorist financing rules, and collects data through those rules, analyzes and reports data to law enforcement. The data it collects is some of the most important data law enforcement has in combatting illicit money flows.

FinCEN has been pushing new requirements and enforcement actions for those deemed to be money transmitters. This has had implications for the CIT industry as well as the banking and ATM industry. … Continue reading

Underlying Deficiencies in BSA/AML Infractions

By Mark Lowers,

In March 2014, Thomas J. Curry, Comptroller of the Currency, spoke before the Association of Certified Anti-Money Laundering Specialists about the Bank Secrecy Act (BSA) and Anti-Money Laundering law (AML) compliance. While he generally spoke positively about the efforts of banking institutions to meet the requirements of the BSA, he was also quick to point out that most of the headlines surrounding banks and the BSA are negative.

In other words, the media will seek out banks that are not in compliance. As a result, the industry as a whole must do more.

Curry noted that BSA infractions can, “almost always be traced back to decisions and actions of the institution’s board and senior management.” The underlying deficiencies that lead to these poor decisions fall into four areas:

… Continue reading