About Jonathan Ferguson

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So far Jonathan Ferguson has created 55 blog entries.

What Did Rabobank Do to Deserve a $50 Million Penalty?

Everyone knows that complying with Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations is a must. However, for this California bank, their deficiencies cost them a $50 million penalty by the Office of the Comptroller of the Currency (OCC). Let's see where they went wrong. Rabobank, N.A., of Roseville, California was subject to a [...]

By |2019-05-30T22:06:32+00:00February 20th, 2018|Blog|Comments Off on What Did Rabobank Do to Deserve a $50 Million Penalty?

Fighting the Continuing SAR Battle

Our most popular blog posts are about writing a knockout SAR narrative (you can find part one here and part two here). But when reviewing suspicious activity reports, we’ve noticed a large number of issues associated with fighting battles known as continuing SARs. As such, it seems that a guide to winning a continuing SAR battle is judicious. What Is [...]

By |2018-02-12T09:00:50+00:00February 12th, 2018|Blog|Comments Off on Fighting the Continuing SAR Battle

Figuring Out What to Say and How to Say It to the Board of Directors is Like Balancing on a Bicycle

"Life is like riding a bicycle. To keep your balance, you must keep moving." -Albert Einstein Successfully riding a bike to get where you want to go requires patience, knowledge, and experience. Determining what to say to your board of directors is like learning how to balance on a bicycle. The “what to say” is [...]

By |2018-02-05T09:00:39+00:00February 5th, 2018|Blog|Comments Off on Figuring Out What to Say and How to Say It to the Board of Directors is Like Balancing on a Bicycle

Three BSA/AML Errors to Avoid

Bank Secrecy Act and Anti-money Laundering (BSA/AML) enforcement is shaping up to be a hot compliance topic this year. We've heard from the NCUA that one of its supervisory priorities for 2018 will be BSA compliance. There are also some big changes coming in just a few months with FinCEN's new customer due diligence and [...]

By |2018-01-29T09:00:57+00:00January 29th, 2018|Blog|Comments Off on Three BSA/AML Errors to Avoid

E-SIGN Refresher Course

The E-SIGN Act has been around since June, 2000. That means its 18th birthday is coming up. As banking regulations go, this isn't exactly new. 18 years is plenty of time for the novelty to wear off and for it to become a commonplace part of your compliance routine. However, that doesn't mean compliance is [...]

By |2018-01-16T09:00:32+00:00January 16th, 2018|Blog|Comments Off on E-SIGN Refresher Course

SAFE Act Exceptions: Compliance Officer's Best Friend?

Dog is Man's best friend, they say, but the fact that "Beware of Dog" signs exist seems to sully the truth of that colloquial phrase. Yes, that snarling and vicious guard dog in your neighbor's backyard might be somebody's best friend, but it doesn't seem to be friendly to humankind in general. It wouldn't take much [...]

By |2018-01-08T09:00:45+00:00January 8th, 2018|Blog|Comments Off on SAFE Act Exceptions: Compliance Officer's Best Friend?

Compliance Culture Scoreboard: Eliminate the Tough Losses

If you're a diehard fan of a sports team, you watch, read and listen to analysis, interviews and reports even beyond the team's actual games. True fanatics will even watch the postgame interviews after a tough loss. In these interviews, reporters love to ask the question, "what went wrong?" The players or coaches almost always [...]

By |2017-12-18T09:00:02+00:00December 18th, 2017|Blog|Comments Off on Compliance Culture Scoreboard: Eliminate the Tough Losses

What Older Consumers Complain About

In the holiday movie classic, National Lampoon's Christmas Vacation, Clark Griswold spends hours covering every inch of his house with strands of lights. Before turning them on, he gathers his family out in front of the house, calls for a drum roll, plugs in the lights, and . . . nothing. The lights don't turn on. [...]

By |2017-12-11T09:00:26+00:00December 11th, 2017|Blog|Comments Off on What Older Consumers Complain About

Front-to-Back AML Validation: How to Envision What You May Be Missing

Originally published on CUInsight.com For those of us who experienced a partial loss of vision at a relatively young age, we likely remember the day that we learned we needed glasses. The process typically began with an elementary school teacher who noticed our permanent squint at the chalkboard. Before we knew it, we were sent to [...]

By |2017-12-04T09:00:44+00:00December 4th, 2017|Blog|Comments Off on Front-to-Back AML Validation: How to Envision What You May Be Missing