UK Beneficial Ownership We have been sharing with our readers for 5 years that a time will come when beneficial ownership – back to human beings, will be required. The UK has taken the first step in that direct … Read More
Articles tagged "BSA"
DOJ Warning of FCPA Legacy Liability
DOJ Warning of FCPA Legacy Liability The Department of Justice - Opinion Procedure Release 14-02 (the “Opinion”)[1] The Opinion stands for the proposition that the DOJ will not penalize a company subject to the … Read More
178 Billion in Fines
178 Billion in Fines 2014 has set a record for fines. According to an article in the Bank Rate 2014 has been the most expensive year on records for fines levied against banks and financial instructions around the … Read More
Exempt Entities
Exempt Entities There are a number of exempt entities from the BSA and AML requirements. Chief amongst these are government and quasi-government accounts. This is a surprise to many, but not to the criminals. … Read More
Russian Sanctions, A Panel Discussion
Russian Sanctions, A Panel Discussion Link to posted discussion http://www.blogtalkradio.com/bekkercompliancechat/2014/07/30/useu-sanctions-v-russia-global-impact-on-the-financial-services-industry This is a link … Read More
Iraqi Dinar
Iraqi Dinar I have watched this rube of an investment idea for years. The heart of the rube assumptions is that the Iraqi dinar will be revalued upward. At 1,168 to the US dollar – it more or less makes sense to … Read More
BNP Paribas
BNP Paribas BNP Paribas is going to get a mighty big fine. The street estimates are in the range of 5 to 10 billion dollars. The bankers are riled up about unfair treatment and are haranguingFrançois … Read More
AML and OFAC Applies to State Governments
AML and OFAC Applies to State Governments I had a short conversation, off the record, with several investigators that work for state unemployment agencies. The common complaint was the inertia with regards to … Read More
Simple Lesson on Bribery
Simple Lesson on Bribery So, we campaign loudly against bribery. Yet some say – ah yes, but when does a gift between friends become a bride? The answer is when the bribe motivates the choice maker to subvert … Read More
Continuous Risk Management for Financial Institutions
Continuous Risk Management for Financial Institutions CRM (Continuous Risk Management) is a discipline that runs through a step-by-step cycle of ‘Identify, Analyze, Plan, Track, Control’ – back to Identify … Read More
Policy Manuals
Policy Manuals Here are a couple of thoughts regarding policy manuals in general All policy manuals are really just documents copied from somewhere else. The copies bring with them all of the biases and … Read More
The Trap Of Perverse Incentives
The Trap Of Perverse Incentives An audit was performed on a regional bank in Asia who was doing a great job on big issues. Compliance was a priority - blocking certain wires and closing a few accounts here and … Read More
Corporate Excuses to Avoid Compliance and Ethics Programs
Corporate Excuses to Avoid Compliance and Ethics Programs by Michael Volkov Change is difficult. I understand that. Business leaders know the importance of change, adaptation and innovation. However, when it comes … Read More
Iranian Sanctions Cause Investment Growth in Georgia
Iranian Sanctions Cause Investment Growth in Georgia A Potential Red-Faced Moment for US and EU Authorities Shaun M. Hassett, CAMS, CDDP A recent Wall Street Journal Article’s opening line reads: “Economic … Read More
Conflict Minerals
Conflict Minerals New Rules On “Hot Rocks” Further Impact Corporations and Financial Institutions The Democratic Republic of Congo (formerly known as Zaire), or DRC, has been called one of the most violent … Read More
“Old MacDonald” of Sanctions Compliance and Customer Due Diligence
“Old MacDonald” of Sanctions Compliance and Customer Due Diligence If you are keeping score, it seems that Sanctions Compliance is a bit like the old nursery rhyme Old MacDonald Had a Farm. You know “…here … Read More
There’s Too Big to Fail, But What About To Small?
There’s Too Big to Fail, But What About To Small? In the Compliance world there is Too Big to Fail… you know, the global financial institutions that are so large that some question whether they are even capable … Read More
Too Big To Jail? Well, Maybe Not
Too Big To Jail? Well, Maybe Not According to a Reuter’s news article, dated March 22, 2013, The U.S. Treasury is changing its previous posture and plans to hold bankers personally responsible (including … Read More
Corruption, How Do We Stop It
Corruption How Do We Stop It Corruption is Fiscal Terrorism? I have seen this argument and we have a good deal of empathy for the assertion and legitimacy in the assertion of the argument. The difference between … Read More
Newest Iranian Sanction Developments
Newest Iranian Sanction Developments US Treasury Advisory: Iran and the Use of Exchange Houses and Trading Companies to Evade U.S. Economic Sanctions against Iran. On January 10, 2013, the U.S. Treasury’s Office … Read More
NACHA Banker
“Its beginning to look a lot like… fraud! During the end of the year with Holiday celebrations, year-end activities and planning for the year ahead, it is also a good time to remind you that the fraudsters are … Read More
HSBC Screwed Up Really Big
Shortly after you read this HSBC will have settled with the US regulators for allowing Iran to launder 250 Billion dollars - yeah $250 billion dollars. How much is that, well it’s just about the same amount of … Read More
Where Policies Fail
Last week, Citibank was cited for failures of its BSA Compliance Program under a cease and desist order issues by the Office of the Comptroller of the Currency (OCC). The Office of the Comptroller of the Currency … Read More
Sanctions and Compliance, A Cautionary Tale…
On February 24, 2012, the US Treasury’s Office of Foreign Asset Control (OFAC) announced the following Civil Money Penalty Information: “Online Micro, LLC Settles Iran Export Apparent Violations: Online Micro, … Read More
FATF 2012 AML Recommendations
On 16 February 2012, the Financial Action Task Force (FATF), the global standard setting body for anti-money laundering and combating the financing of terrorism (AML/CFT) , published the following public documents, … Read More