Spectrums Within the Spectrum Water is an amazing thing. In fact, it is a very unusual substance. Think about it. Ice floats in water. Try and find another substance where such occurs and you might be searching for a long time. Ask almost any U.S. citizen at what temperature water freezes and they’ll probably tell [...]
Learning From The Ripple Effect—Virtual Assets and Virtual Asset Service Providers I have always been fascinated by the ripple effect. Throw a stone, preferably large, into an otherwise calm body of water, and the result is striking. Circular waves move out evenly in all directions, rippling outward from the impact of the dropped stone. One [...]
80s Nostalgia and BSA/AML Image by Aakansha Trivedi via Wikipedia Watching Stranger Things (Netflix series in its 4th season) has added enjoyment for those of us who grew up during the time frame presented in the series. I’m especially fascinated by the references to D&D. For those who weren’t teenagers in the 80s, [...]
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 [...]
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 [...]
This trade-based money laundering scheme involved shell companies in Mexico and the U.S. and batches of obsolete cell phones, generating more than $100 million in illicit funds. by Dayne Bloxham AdvisX When it comes to identifying suspicious transactional activity, knowing what to look for is half the battle. FinCEN recently highlighted an example [...]
by Ken Agle AdvisX 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 [...]
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 [...]
Imagine two scenarios. In the first, you fly to a beautiful, remote island for a carefree week at an exclusive and all-inclusive resort. You spend the week soaking up sun on the beach, enjoying fine dining, and snorkeling in the crystal clear water. Now for scenario two. Same beautiful island, but this time, there's no [...]
