On July 24th, 2019, the OCC issued Bulletin 2019-37 Operational Risk: Fraud Risk Management Principles. The OCC guidance can be broken down into two separate components: governance and risk management operations. The governance component includes: Culture Ethical standards and employee accountability. Infrastructure Policies, procedures,…
In Parts 1 and 2 of this series, we discussed how TRANSPARENCY in BSA compliance is critical to maintaining banking relationships and how PROCESS in BSA risk management will demonstrate to the toughest audience (your bank) that you manage money…
In Part 1 of this series, we argued that Transparency into your BSA/AML risk management is a key to building and maintaining banking relationships. MSB relationships can be profitable to banks and MSBs serve traditionally underserved populations. That’s good. But many FIs…
Fear: “A distressing emotion aroused by impending danger, whether real or imagined…” Money transmitters and other MSBs experience real fear of derisking while banks and credit unions experience what could be imagined fear of banking MSBs. We know money transmission can be higher…
Best Practice BSA/AML Risk Assessment The cost of the annual risk assessment process, which we covered in parts 1 and 2 of this series is just one facet of the risk assessment issue. As discussed in the two previous articles,…
Risk Assessment Costs and Observations Review of the Foundation: As discussed in the previous article, the BSA risk assessment is the cornerstone of the BSA program. Since all activities in the lifecycle of the BSA process flow from the risk assessment,…
Risk assessment is the cornerstone of the BSA program development. Since all activities in the lifecycle of the BSA process flow from the risk assessment, it is something that can make all the difference in the success of your BSA…
BSA and OFAC compliance are typically handled by our federal regulator/insurer (FDIC, NCUA, etc.). Why is DFS involved? According to Part i504.1, DFS found “shortcomings” in the transaction monitoring (BSA) and filtering (OFAC) programs used by DFS-regulated institutions and elected to…
We recently wrote that “transaction laundering” could be the money laundering and fraud issue of 2019 and beyond. The Financial Timessays transaction laundering is a $200 billion per year scheme in the United States alone and that number is expected to increase…
Transaction laundering could be the money laundering and fraud issue of 2019 and beyond. The Financial Timessays transaction laundering is a $200 billion per year scheme in the United States alone and that number is expected to increase (perhaps exponentially) over the…