Suspicious Activity Reporting and Business Email Compromise

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 [...]

By |2019-08-23T11:17:29+00:00August 23rd, 2019|Blog, Compliance Tips|0 Comments

True Beneficiaries and BSA

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 |2019-08-14T15:51:02+00:00August 14th, 2019|Compliance Tips|0 Comments

How SARs Helped Bring Down a Scam Biodiesel Fuel Producer Network

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 [...]

By |2019-06-19T16:15:28+00:00June 19th, 2019|Compliance Tips, Uncategorized|0 Comments

Next Level Risk-Based Pricing is Coming: Beyond Decisioning and Pricing is Outcome Analysis

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 [...]

By |2019-05-30T22:12:39+00:00October 25th, 2018|Blog, Compliance Tips|Comments Off on Next Level Risk-Based Pricing is Coming: Beyond Decisioning and Pricing is Outcome Analysis

Compliance Abhors a Vacuum – If the Void Is Filled with Heightened BSA Scrutiny, Would You Be Ready?

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 [...]

By |2018-07-31T11:03:56+00:00July 31st, 2018|Compliance Tips|Comments Off on Compliance Abhors a Vacuum – If the Void Is Filled with Heightened BSA Scrutiny, Would You Be Ready?

In Search Of Compliance Independence From Your ISO? (Good Luck With That)

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 [...]

By |2018-04-18T11:11:58+00:00April 18th, 2018|Compliance Tips|Comments Off on In Search Of Compliance Independence From Your ISO? (Good Luck With That)

The Wheels on the BSA Go Round and Round: In Pursuit of the Well-Written SAR Narrative (Part 2)

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. [...]

By |2018-01-22T09:00:51+00:00January 22nd, 2018|Blog, Compliance Tips|Comments Off on The Wheels on the BSA Go Round and Round: In Pursuit of the Well-Written SAR Narrative (Part 2)

In Pursuit of the Well-Written 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 [...]

By |2017-08-25T09:00:46+00:00August 25th, 2017|Blog, Compliance Tips|Comments Off on In Pursuit of the Well-Written SAR Narrative

Social Media and Your Financial Institution: Why and How

In the age of digital media marketing, regulators continue to turn their heads toward social media use. Whether your financial institution has embraced social media marketing or not, best practices for risk management recommend having social media procedures for current or potential future use. Here we take a look at different aspects of social media and what [...]

By |2016-07-18T08:46:07+00:00July 18th, 2016|Blog, Compliance Tips|Comments Off on Social Media and Your Financial Institution: Why and How

Two Definitions to Help you Understand FinCEN’s Customer Due Diligence Requirements

Originally published on CU Insight. At present, banks and credit unions are not required to know the identity of the individuals who own and/or control their legal entity customers or members. FinCEN and the federal law enforcement agencies have long seen this as a weakness in the BSA/AML programs that financial institutions are required to [...]

By |2016-07-11T10:57:40+00:00July 11th, 2016|Blog, Compliance Tips|Comments Off on Two Definitions to Help you Understand FinCEN’s Customer Due Diligence Requirements