Top 10 Risk Management Articles from 2015

By Lowers & Associates,

risk management

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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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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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:

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