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

4 Red Flags of Money Laundering or Terrorist Financing

By Lowers & Associates,

One of the most important aspects of BSA/AML compliance is the responsibility it places on regulated financial entities to report suspicious transactions. This responsibility requires an organization to be able to monitor and identify transactions, evaluate them in real time, and flag the ones that are suspicious. In many cases, a Suspicious Activity Report (SAR) should be filed with the Financial Crimes Enforcement Network (FinCEN).

Financial organizations need to build AML compliance systems that assist trained employees to flag suspicious transactions as efficiently as possible. Internal controls and procedures should have the means to recognize clues that a transaction is potentially illegal, and ensure that employees know it. There are a number of factors these controls would monitor, mostly concerning a customer’s behavior. … Continue reading

  Category: Compliance, Risk Management
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5 Key Components of a BSA/AML Compliance Program

By Lowers & Associates,

financial-security

You are most likely familiar with the Financial Crimes Enforcement Network (FinCEN) which is a bureau of the Treasury Department. FinCEN’s mission is “to safeguard the financial system from illicit use and combat money laundering and promote national security” through the use of financial services information.

Bank Secrecy Act (BSA) Anti Money Laundering (AML) regulations previously applied to banks and credit unions, but over the past three decades the law has been expanded to cover a very wide array of financial institutions, maybe even yours. Today, FinCEN maintains webpages for money services businesses (MSB), depository institutions, the insurance industry, securities and futures, casinos, and more. … Continue reading