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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The United States imposes sanctions against foreign governments, individuals, and organizations to achieve specific foreign policy objectives, either unilaterally or as part of a coalition. Since these sanctions have the force of law, they prohibit or restrain certain actions of ordinary U.S. persons (citizens and permanent residents), companies, and organizations that might have dealings with the foreign entities. The government publishes a list of foreign countries, persons, or organizations (Specially Designated Nationals, or “SDNs”) whose assets are blocked and who cannot be part of a transaction.

Sanctions are administered and enforced by the Department of the Treasury’s Office of Foreign Assets Control (OFAC). It’s important to understand that OFAC operates under the President’s national security mandate, so it has wide latitude to devise and enforce guidelines for financial institutions’ compliance. The coverage of this authority is very broad, including all U.S. persons and organizations, including foreign branches. It even prohibits a U.S. entity from facilitating a sanctioned activity by a 3rd party foreign entity. … Continue reading