BSA Compliance: The Dangers of Letting it Get Too Ordinary

Humans have a remarkable ability to get used to things. For example, on a trip to Yellowstone National Park several years ago, I saw a group of people excitedly pointing to something off in the distance. They had cameras out and were acting as if they were seeing Sasquatch. However, when I got close enough to see what they saw, I realized it was only a few mule deer. The people admiring the deer, it turned out, were from a large urban city outside of the United Continue reading →

Comparative File Review: See the Whole Iceberg

It’s common knowledge that the part of an iceberg that can be seen above the surface is just a small portion of the whole iceberg. In fact, about 90 percent of the iceberg is hidden below the water’s surface. If you are trusting your fair lending risk to just the data visible on the surface, there is a lot that you’ll miss. In our last post, we described how a regression analysis can be used to see more of your data that is hidden below the Continue reading →

The Elephant in the Room: Fair Lending Regression Analysis

We’ve all heard the expression, “how do you eat an elephant? One bite at a time.” The inventor of this phrase must have been marooned and starving on an elephant-infested island, because seeing an elephant and wondering, “how am I going to eat that thing?” is not exactly a normal reaction. Even an avid steak-eater likely doesn’t see a cow and immediately wonder how to eat it. But however it happened, someone noticed that attempting to eat the world’s largest land animal in one go Continue reading →

The Top 5 Posts of 2016

2016 is just about gone, but there’s still just enough time to look back and see where we’ve been. Here’s a look back at the top 5 most popular blog posts of 2016. 1. FinCEN’s Top 3 Money Laundering Concerns The fight against money laundering and terrorist financing in the U.S. is an ongoing and evolving battle. That’s why every year FinCEN produces a new National Money Laundering Risk Assessment from the Department of the Treasury. In an analysis of more than 5,000 law enforcement cases and Continue reading →

Fair Lending Model Validation: Strengthening Your Fair Lending System

Pendulums tend to swing, and the Fair Lending pendulum is no exception. Over the last few years, with the transition of HMDA rulemaking to the Consumer Financial Protection Bureau, and with the CFPB’s new final rule expanding HMDA data collection requirements, it’s clear that the pendulum has been swinging toward a tougher regulatory environment. With the change in administration, however, it appears that the pendulum is going to be heading back the other way. Precisely when and how far it will swing remains to be Continue reading →

The Third Dimension of an AML Risk Assessment

Originally published on When I was young, a teacher shared an analogy that has always stuck with me. I can’t exactly remember what she called it, but I’ve taken to calling it “2-D Bob Meets 3-D Jill.” My teacher started by sketching a diagram on the board that looked something like this. Bob has invited some friends over to play cards. Everything in Bob’s world is 2-D, including Bob, his friends, the card table, the cards, and even Bob’s house. Everything exists on a Continue reading →

The Look-Back Project: An AML Marathon

The annual New York City Marathon is just a little over two weeks away. If you’re planning on running in it, you hopefully began training many months ago. Unless you’ve got some superhuman characteristics, the average person can’t simply run a marathon on a whim, without any training. However, if information comes to light that indicates your financial institution has some holes in its AML monitoring process and may have missed some suspicious transactions, you could suddenly be feeling like you have to run a Continue reading →

Two Years and No SARs/CTRs? Someone May Be Eyeing You as a Weak Link

Yes, summer is already over and fall is upon us. That means sweater weather, changing leaves, and pumpkin spice. But it also means the year is winding down. If it was your New Year’s resolution to file at least one SAR this year, time is getting short. And if you still haven’t filed any, it might be time to double check to make sure you aren’t missing anything. If it’s been awhile since your financial institution has filed a CTR or a SAR, you may Continue reading →

Validation: The Pièce de Résistance of Anti-money Laundering

Originally published on Even the best kitchen in the world—equipped with a brick oven, top-of-the-line equipment, and the sharpest knives—can’t turn a bad cook into a great one (even though it could help). The substandard cook still needs to learn some critical cooking skills before the dream kitchen can produce the pièce de résistance. So it makes sense that even the best anti–money laundering (AML) monitoring system in the world—perfectly optimized with no expense spared for the most current technology and automation—can’t guarantee effective Continue reading →

Hey Batter Batter, Swing! Good Training Practices for AML Monitoring

Spring training for Major League Baseball is long over, the regular season is winding down, and playoffs will soon be upon us. Over the course of a long season, the teams that spent their time during spring training actually training and preparing frequently find that it makes the difference between being a playoff contender and an also-ran. In a similar fashion, efforts to thoroughly validate an anti-money laundering system can pay off in the long run. How do you achieve a strong AML system? Here are four Continue reading →