For many Bank Secrecy Act officers and their boards of directors, the thing that haunts their dreams most is their examiners finding some suspicious transactions that should have been investigated, but weren't. If such transactions are found, what typically follows are two questions along the lines of: Why weren't these transactions identified by the institution [...]
Advances in technology make it difficult to know what is safe and who to trust, especially for the elderly population. This makes them prime targets for fraudsters. In fact, it is estimated that about 5 million seniors were swindled for nearly $3 billion in the last year alone. Taking this down to a more individual [...]
FinCEN, the Financial Crimes Enforcement Network, doesn't publish too many alerts. In fact, for the first half of 2019, it had published only nine news items. So when it published three on a single day in July 2019 on one subject alone, it's clear that one subject had gotten its attention. The focus of this [...]
FinCEN recently highlighted the work of a financial institution that involved Suspicious Activity Reporting and Currency Transaction Reporting as it pertains to true beneficiaries. In this case, the bad actors recruited heroin addicts to steal certain types of goods from stores in the Chicago area. They exchanged their stolen goods for cash from small stores [...]
by Ken Agle The more front line and BSA personnel understand about the how Suspicious Activity Reporting and Currency Transaction Reports fit into the overall equation of tracking down criminals, terrorists and other bad actors, the more likely it is for a financial institution’s BSA program to be effective. Understanding context helps keep BSA reporting [...]
When economic times are good and funds are relatively easy to lend without meaningful short-term risk, most financial institutions find themselves in strong positions from a credit risk and earnings perspective. Yet, the tough lessons of lending and risk over the past 30 years have taught us many times over that economic cycles repeat. It’s [...]
Originally appeared in CBIZ Insights While a climate of regulatory relief sweeps across the industry, it is a prudent compliance officer who keeps both feet on the ground and considers what risks such a climate could possibly present. Beyond awareness that regulatory enforcement is cyclical and subject to potentially rapid changes based on external or [...]
In banking, disclosures matter, especially when it comes to credit cards. The rules, and they are not a few, are specifically spelled out in great detail. Where it can get a little fuzzy is when third parties enter the equation. This is especially true with third parties known as independent service organizations, or ISOs, as [...]
Consider your BSA program as one of the wheels that supports the vehicle that is your compliance program. Within this wheel, there are several smaller components—the rim, axle, and spokes could perhaps be considered due diligence, training, and suspicious activity monitoring. For BSA, one of these crucial pieces is the suspicious activity report (SAR) narrative. [...]
Suspicious Activity Report (SAR) narratives can be one of the more problematic areas of BSA compliance. However, not only are SARs an important tool for government authorities to help fight criminal financial activity, they frequently trip up financial institutions in examinations, leading to potentially costly fines and an adverse impact on their reputations, which is [...]
