The AdvisX blog.

Beneficial Ownership and the Dark Side of the Moon

Originally published on In the world of Bank Secrecy Act (BSA) and Anti-Money Laundering (AML), it all comes down to perspective. For many financial institutions, the perspective sometimes becomes locked down tight. Day in and day out, the systems look at the same things over and over again. In a sense, it’s like they’re [...]

By |2017-05-01T16:50:24+00:00May 1st, 2017|Blog|0 Comments

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 [...]

By |2017-01-30T12:00:45+00:00January 30th, 2017|Blog|0 Comments

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, [...]

By |2017-01-17T10:00:46+00:00January 17th, 2017|Blog|0 Comments

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 [...]

By |2017-01-09T10:00:44+00:00January 9th, 2017|Blog|1 Comment

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 [...]

By |2016-12-12T10:00:15+00:00December 12th, 2016|Blog|0 Comments

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 [...]

By |2016-11-14T09:14:14+00:00November 14th, 2016|Blog|0 Comments

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 [...]

By |2016-10-24T10:48:09+00:00October 24th, 2016|Blog|0 Comments

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 [...]

By |2016-09-19T09:20:13+00:00September 19th, 2016|Blog|0 Comments

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. [...]

By |2016-09-06T17:11:22+00:00September 6th, 2016|Bank Secrecy Act/Anti-Money Laundering, Blog|0 Comments