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…

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…

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…

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…

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 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…

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…

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…

The FFIEC started the list of higher-risk products, services, and customers in its BSA/AML Examination Manual: Office of Foreign Assets Control—Overview. Presenting the list (see also 31 CFR Part 501), FFIEC said: …