The end of the year is a great time to reflect and with that, we like to share our most-read articles of the year. This year’s top articles highlight a strong focus on workplace violence risk management, including active assailant concerns. More than ever, prediction, preparation, and prevention measures are needed to keep each workplace safe. Take some time to read through our top risk management articles from 2016 and plan for a safer and more productive 2017.
1. [Infographic] How to Address the Threat of an Active Assailant Incident in Your Organization
Each and every employee and community member deserves to feel safe. OSHA requires it, labeling it as an organization’s responsibility to provide a safe workplace. Tragically, with a growing number of active assailant incidents happening all around the country, this threat is more relevant than ever before. Over a two-year span, 26 states experienced 40 active assailant incidents, resulting in more than 230 casualties.
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2. Building a Culture of Compliance around BSA/AML – Guidance from FinCEN
In simpler times, the Bank Secrecy Act (BSA) regulated the Anti-Money Laundering (AML) activities of banks, as the name implies. In our globalized and networked world, it has expanded to cover financial institutions ranging from the biggest banks to mom and pop check cashing, or money transfer operations running out of storefronts in a mall. The Financial Crimes Enforcement Network (FinCEN) has launched actions against businesses across this spectrum for violations of BSA/AML requirements.
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If you run a business that facilitates or conducts money transactions, or transactions in other liquid commodities, you are no doubt aware of FinCEN. Rest assured that FinCEN is aware of you, too. And we predict it’s only a short matter of time before their foreshadowing of AML enforcement actions against the cash servicing and transport industry becomes a harsh reality.
The Financial Crimes Enforcement Network (FinCEN) is the arm of the U.S. Treasury charged with investigation and enforcement of Bank Secrecy Act provisions intended to block the financial sources of illegal and terrorist organizations. Traditionally, the BSA applied to common financial institutions like banks and credit unions. But as banks began to offload services to third party vendors and the number of money-related businesses like check cashers and wire transfers proliferated, the BSA has been applied to an ever-wider array of businesses.
Most of these newer businesses are collectively known as Money Service Businesses (MSB). Businesses that transmit money, issue money orders, cash checks, deal in foreign currencies, or a number of other types of transactions, are required to register with FinCEN and maintain an effective Anti-Money Laundering (AML) program. … Continue reading
As 2015 comes to a close, we are pleased to share our most popular articles from the Risk Management Blog in 2015.
1. 4 Red Flags of Money Laundering or Terrorist Financing
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).
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2. 5 Key Components of a BSA/AML Compliance Program
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.
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3. The Important Role of Internal Controls for AML Compliance
It is well understood that money launderers use deceit or theft to capture the processes of financial entities for illicit purposes. As a result, your AML compliance program must implement internal control designs that increase the chances of preventing or detecting such activities.
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“Use of third parties reduces management’s direct control of activities and may introduce new or increase existing risks, specifically operational, compliance, reputation, strategic, and credit risks as well as the interrelationship of these risks. Increased risk most often arises from greater complexity, ineffective risk management by the bank, and inferior performance by the third party.” – Office of the Comptroller of the Currency, October 30, 2013 Bulletin
It’s well established that banks are increasingly turning to third parties to handle a wide range of activities and processes, from cash transport and ATM replenishment to IT and other services. However, when you examine the latest standards and scrutiny placed on financial institutions by the FDIC, CFPB, FFIEC, OCC, FinCEN, and others, it is clear that whether the activities are being performed by the bank itself or a third-party vendor, it’s the bank that carries the bulk of the risk. … Continue reading
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