the AffirmX blog
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 [...]
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 [...]
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 [...]
"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 [...]
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 [...]
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. [...]
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 [...]
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 [...]
2017 is just about gone, but there’s still just enough time to look back and see where you’ve been. Here’s a look back at the top 5 most popular blog posts of 2017. 1. Don't Strike Out: 5 Common SAFE Act Violations and How to Avoid Them Babe Ruth is considered by many to be [...]
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 [...]
