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BSA Officers overseeing either a new AML program or overhauling an old one understand they must look to the basics to ensure compliance. As outlined in this post, regulators look for the implementation and results of each of the five pillars of BSA: internal controls, designation of a BSA Officer, periodic BSA training, and ongoing customer due diligence (CDD). This blog post covers the key takeaways related to each pillar.
Robust quality control processes for AML/CFT programs are a safeguard against failures of suspicious activity monitoring programs. Like AML/CFT programs themselves, AML quality control should be tailored to a financial institution’s risk. Another critical component is documentation and regular quality control reviews. In this post, the director of Abrigo’s financial crimes investigation unit describes what a solid QC program looks like.
A board member who doesn’t understand the Bank Secrecy Act (BSA) and your AML/CFT program is a board member who may not understand their role in an institution’s AML and fraud efforts. A lack of understanding, in turn, can affect much-needed resources. Like staff, board members need annual, customized training. Abrigo Senior Financial Crimes Investigator Tiffany McLain, CAMS, explains in this post what to include in yearly board training. Following her tips will help board members see the program from a high level and understand risks across the bank, credit union, or non-bank financial institution.
Elizabeth Rosenberg, the U.S. Treasury Assistant Secretary for Terrorist Financing and Financial Crimes, noted in a recent speech that financial institutions have played an essential role in denying Russia the financial means to wage war on Ukraine. “[R]eports, analysis, and typologies you develop identify and enable us to understand better the evolving risks associated with illicit Russian finance and are paramount in keeping the pressure on Russia to cease their violence,” Rosenberg said. This post by Abrigo Compliance and Engagement Director Terri Luttrell, CAMS-Audit, describes regulator expectations related to five components of effective sanctions compliance.
Piggybacking. Bust Outs. These are just two schemes associated with synthetic identify fraud, or synthetic ID fraud – the fastest-growing type of financial crime in the U.S. Read this post to learn about actual synthetic ID fraud cases and the general impact of synthetic ID fraud. Understand three steps banks and credit unions can take to protect their customers or members and their institutions against synthetic identity fraud.