IIBA Charlotte Metro Chapter Meeting: CapTech AML … economy to give the ... WTU made several payments totaling $450,000 for “onsulting Services” to a fake ... Evolving Technologies

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IIBA Charlotte Metro Chapter Meeting:

CapTech AML PresentationSeptember 2017

Introduction ExecutionRegulation and

Governance

Agenda

Money Laundering Introduction

• What is Money Laundering and how does it work?

AML Regulation and Governance

• How is Anti-Money Laundering regulated and governed?

AML Execution

• Who executes Anti-Money laundering, how do they do it, and how does it apply to Business Analysis?


Governance

Money Laundering Introduction

• What is Money Laundering?

• The methods in which people or entities conceal the existence, illegal source, movement, destination or illegal application of property or funds obtained from criminal activities and making them appear legitimate.

• What is Terrorist Financing?

• The methods in which people or entities collect and provide funds with the knowledge that they will be used to assist in terrorist acts

• Terrorist Financing and Money Laundering share similar methods to move funds, but the desired outcome/purpose is different

• What is the difference?

• Origin of Funds and intent

• Terrorist Financing can stem from legitimate sources (Wealthy Donors, Religious Orgs.) for illegitimate purposes

• Money Laundering uses illicit funds for legitimate purposes (Integration Phase)

• Overall, it is easier to detect Money Laundering as it is easier to determine the source of funds as opposed to the future use of funds

• How is Money Laundering conducted?

Sources: ACAMS, FINRA, CapTech AML Experience

Placement Layering Integration

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Governance

Money Laundering Phase 1 – Placement

Placement - Physical disposal of dirty money derived from criminal activity.

• Breaking up large amounts of cash into smaller sums and then depositing into a bank account.

• Currency transaction report (CTR) is a report that U.S. financial institutions are required to file with FinCEN for each deposit, withdrawal, exchange of currency, or other payment or transfer, by, through, or to the financial institution involving a transaction in currency > $10,000 on the same day.

• Structuring – Any purposeful attempt to break up or split cash transactions to evade the above mentioned CTR thresholds could be considered structuring and could potentially be filed on a Suspicious Activity Report (SAR).

• Aggregation

• Smurfing

Sources: ACAMS, CapTech AML Experience

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Governance

How Financial Products can be Leveraged in the ML Placement Phase

Example Placement

Checking & Savings Accounts(Chase, Wells Fargo, BofA)

Depositing the cash (dirty money) into the bank, and structuring to conceal its existence.

Personal & Business Loans(Various Banks)

Using dirty money as collateral for a domestic loan.

Money Service Business(Money Transfer/Remitters, Monetary Instruments)

Present cash (dirty money) to MSB and potentially structure to conceal its existence.

Insurance Companies(MetLife, Northwestern Mutual, State Farm)

Cash (dirty money) can be used to fund a policy, however this is becoming less common and more difficult, due to ML concerns.

Securities Brokers/Dealers(Raymond James, Ameriprise, LPL Financial)

Cash (dirty money) can be used to fund an investment account, however this is becoming less common and more difficult, due to ML concerns.

Casinos & Gambling Operations(MGM, Harrahs)

Ability to exchange cash (dirty money) for chips.

High Value Items (Precious Metals, Jewelry, Art)

Purchase of high dollar items with cash (dirty money).

Vehicle Dealers/Sellers(Car Dealerships & Used Car Dealers)

Vehicle Dealers have been known to under report or not report the use of currency to pay for vehicles, thus failing to report to governing bodies and accepting laundered money.

Source: CapTech AML Experience

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Governance

Money Laundering Phase 1 – Placement: Potential Structuring Scenarios

Example 1:

Ward Wood comes into the branch 4 days a week and always withdraws $9,500 in cash from his accounts. This behavior has occurred for 3 straight weeks.

• Is this structuring?

• What other information would be helpful?

• What should the financial institution do in this situation?

Example 2:

Mike Shockey comes in Monday through Friday and deposits between $7,000 and $9,600 in cash on behalf of Mike’s Margaritas. This has occurred for 2 months.

• Is this structuring?

• What other information would be helpful?

• What should the financial institution do in this situation?


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Governance

Money Laundering Phase 2 – Layering

Layering – Separation of illicit proceeds from their source by layers of financial transactions intended to obfuscate (conceal origin).

• Illegal money has just entered the financial system and the goal is to move the money around swiftly to help prevent suspicion and tipping off law enforcement.

• Electronic transfers to multiple accounts.

• Convert deposited cash to Money Instruments.

• Place money in investments.

• Reselling high-value goods.

• Using Shell banks.


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Governance

How Financial Products can be Leveraged in the ML Layering Phase

*Self-Dealing Loans are quite common - receive loan from off-shore account and then pay the interest to themselves using proceeds from illicit activities.

Example Layering


Transfer the funds into different products/services to further conceal its origin.

Credit Cards(Capital One, Chase, Citi)

Prepaying or overpaying a card & requesting a refund.

Personal & Business Loans*(Various Banks)

Utilize the cash (dirty money) to pay the monthly loan amount and in essence creating a self-dealing loan.


Cash from customers are transferred to other parties or into monetary instruments.


Overfunding insurance products (Annuities or Life Insurance) with the use of dirty cash in other financial accounts – paying early and often.


• Ability to hold funds in a trading account without actively trading.• Using “wash trading” to give the appearance of trading and thus helping to mask the true source

of funds through additional complex transactions.


Due to a fairly stable market and resale value, these items can be help for a period of time and resold, which helps to obfuscate the original transaction.


Trading in vehicles and conducting successive transactions of buying and selling new and used vehicles to produce complex layers of transactions.


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Governance

Money Laundering Phase 3 – Integration

Integration – Process of re-entry of illicit wealth into the economy to give the appearance of normal business funds.

• Helps provide apparent legitimacy to ML activity and paints a better picture of normalcy for the criminal.

• Invest funds or purchase real estate, luxury assets, or business ventures.


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Governance

How Financial Products can be Leveraged in the ML Integration Phase

Example Integration


Liquidation/withdrawals from various bank accounts through re-entry into market by purchasing goods/services.

Credit Cards(Capital One, Chase, Citi)

Receiving a refund on prepayment or overpayment – cleansed check.

Personal & Business Loans(Various Banks)

Using loan funds for legitimate purposes to give the appearance of cleansed funds being used.


Money is received by the beneficiaries either through cash transfer or through a monetary instrument.


Requesting early cancellation or redemption in an effort to receive a cleansed check.


Liquidation/withdrawals from various investment accounts through re-entry into market by purchasing goods/services.

Casinos & Gambling Operations(MGM, Harrahs)

Cash out in the form of a cleansed casino issued check.


Allows for the funds to be cleansed through re-selling.


Down Trading - Vehicle Dealers have been known to allow individuals to trade-in more expensive cars for a cheaper model and then receive a cleansed check for the difference.


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Governance

Reinforcement on the three phases of money laundering from Saul Goodman.

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Governance

Examples of Money Laundering – Embezzlement & Lack of Controls

Source: Washington Post

Several officials of the Washington DC Teachers Union (WTU), including president Barbara A. Bullock, were implicated in a scandal involving the theft of $4.6 million from the WTU coffers. Some of these embezzlement and ML techniques were fairly simple and are outlined below:

• Checks issued to creditors such as Verizon or the DC Treasurer had the payee crossed out and replaced with the name of Bullock’s chauffeur Leroy Holmes for over 200 checks.

• Holmes often left Independence Federal Savings Bank with his pant pockets filled with cash up to $20,000. This bank was ultimately swept into the ML charges for colluding with WTU. This bank failed to complete certain regulatory forms for these transactions.

• What forms were avoided by the bank?

• Through the direction of Bullock, WTU made several payments totaling $450,000 for “Consulting Services” to a fake company called Expressions Unlimited.

• One of the partners of the company was Michael Martin, Bullock’s hairdresser.

• At the instruction of Bullock, WTU credit cards were used to buy expensive clothing, electronic equipment, artwork, and other expensive items.

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Governance

Evolving Technologies & Impact to AML & Regulation


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Evolving Technology

Examples Advantages to Money Launderers Impacts to Financial Institutions & Regulators

How the 3 stages of Money Laundering can be utilized

Online Banking Services

Online Transfers,Online Check Deposits

Ease, Speed, Anonymity, Distance

24 hour account access and related services

In-person Branch interactions & CTRs are less effective

Less awareness of who is actually controlling the account (KYC at risk)

Difficult to match the customer with identification documentation

Placement – Difficult as most cyber banks don’t allow deposits

Layering – Easy as encryption and ease of access makes this stage quite simple

Mobile Payment Services

Amazon Cash,Venmo, PayPal

Little verification, identification and monitoring of users and transactions

Ease, Speed, Anonymity, Distance

24 hour account access and related services

Source of funds can be complex when re-entering the financial institution

Illicit funds could be used to purchase goods with little verification and identification of the users

Integration – Moderate to Easy – Creation of PayPal, Venmo, and Smart-Cards allows the money to be moved to other individuals and ATMs worldwide

Crypto-currenciesBitcoin, Ether, Litecoin

Ability to transfer funds internationally with little to no fees, exchange rates or tax

Allows for quick and easy transactions off of Financial Institution and Government ledgers

Inability to view financial transactions that are completely “off the grid”

Source of funds still heavily relies on traditional banking systems, so that is a key area for regulators to focus

Placement - Difficult as most crypto-currencies still require money from a financial institution to purchase the currencyLayering – Easy as anonymity and encryption make this stage even simplerIntegration – Moderate as full acceptance/adoption has not occurred

Blockchain Bitcoin, Ethereum,Litecoin, Zcash, Komodo

Allows for a network of databases for Money Laundering encryption, uniqueness, immutability and consensus

Blockchain could be appropriated and used by Financial Institutions and Regulators to have the same advantages as those for Money Launderers

Placement, Layering – Difficult as Financial Institutions could share all deposits and transactions recorded daily, across the world with each other and the government

Integration – Difficult as vendors could provide data to the blockchain on purchasing of high value items or items prone to Money Laundering & Terrorist Financing

• Articles for Additional Research:• http://timesofoman.com/article/83481• http://www.cs.utah.edu/~kmay/look/digital/Laundry.htm• http://www.marketwatch.com/story/bitcoin-ether-and-other-cryptocurrencies-may-be-seeing-the-beginning-of-the-end-2017-09-06

http://timesofoman.com/article/83481

http://www.cs.utah.edu/~kmay/look/digital/Laundry.htm

http://www.marketwatch.com/story/bitcoin-ether-and-other-cryptocurrencies-may-be-seeing-the-beginning-of-the-end-2017-09-06

AML Regulation & Governance


Governance

Anti-Money Laundering – Regulation and Governance Overview

• How is Anti-Money Laundering Regulated?

• The US Federal Government and International Legislative Bodies develop and maintain AML laws to ensure consistent rules are in place for Anti-Money Laundering.

• AML Regulation is extremely complex, as there are a multitude of AML laws that are in place, with complicated applicability across other laws and by type of financial institution.

• How is Anti-Money Laundering Governed?

• The US Federal Government and International Legislative Bodies rely on various governing and enforcing groups to ensure that Anti-Money Laundering regulation is being executed upon by the institutions those laws apply to.

Additional Reading: https://www.protiviti.com/sites/default/files/united_states/insights/guide-to-us-aml-requirements-6thedition-protiviti_0.pdfSources: OCC, FINRA, CapTech AML Experience

AML Regulation (Bank Secrecy Act, USA Patriot Act, FFIEC Laws etc.)

AML Governance (Office of the Comptroller of the Currency, FINCEN etc.)

Financial Institutions (Capital One, Wells Fargo etc.)

Customers (Individual Customers and Legal Entities)

High level AML regulatory structure:

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https://www.protiviti.com/sites/default/files/united_states/insights/guide-to-us-aml-requirements-6thedition-protiviti_0.pdf


Governance

Regulation Overview: Bank Secrecy Act

"Firms must comply with the Bank Secrecy Act and its implementing regulations ("Anti-Money Laundering rules"). The purpose of the AML rules is to help detect and report suspicious activity including the predicate offenses to

money laundering and terrorist financing, such as securities fraud and market manipulation.”

Content Sources: FINRA, Protivity AML Guide, CapTech AML Experience

• What is it?

• The key US AML legislative framework, commonly known as BSA, or BSA/AML.

• Established in 1970 and amended in 2001 by the USA Patriot Act, it is a series of laws passed by Congress to help regulate and stop money laundering in the United States.

• What does it require of Financial Institutions?

1. Regulatory Reporting for Financial Institutions to report suspicious activity to the government (ex. Currency Transaction Reports, Suspicious Activity Reports).

2. Recordkeeping Requirements to identify the source, volume or movement of currency or monetary instruments into or out of the US or deposited into Financial Institutions.

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Governance

Regulation Overview: USA Patriot Act

“The Department of Justice's first priority is to prevent future terrorist attacks. Since it’s passage following the September 11, 2001 attacks, the Patriot Act has played a key part - and often the leading role - in a number of successful operations to protect

innocent Americans from the deadly plans of terrorists dedicated to destroying America and our way of life. ” - Justice.gov

Sources: FINCEN, Protivity AML Guide, CapTech AML Experience

What is it?

• According to FINCEN, it is the “United and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001.”

• The USA Patriot Act made significant changes to ML regulations (including the BSA), imposed enhanced requirements for AML programs, and expanded the scope of AML coverage to NBFIs (Non-Banking Financial Institutions (ex. Insurance Company).

• Enacted after the 9/11 Terrorist Attacks, the USA Patriot Act (specifically Title III) deals with both Money Laundering and Terrorist Financing.

What does it require of Financial Institutions?

1. A system of internal controls to ensure ongoing compliance.

2. Independent testing of BSA/AML compliance.

3. Designate an individual or individuals responsible for managing BSA compliance (BSA compliance officer).

4. Training for appropriate personnel.

5. A Customer Identification Program must be included as part of the BSA/AML compliance program.

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https://www.fincen.gov/resources/statutes-regulations/usa-patriot-act


Governance

Governance Overview: Office of the Comptroller of the Currency (OCC)

The OCC has the power to: 1) Examine the national banks and federal thrifts. 2) Approve or deny applications for new charters, branches, capital, or other changes in corporate or banking structure. 3) Take supervisory actions against national banks and federal thrifts that do not comply with laws and regulations or that

otherwise engage in unsound practices. Remove officers and directors, negotiate agreements to change banking practices, and issue cease and desist orders/civil money penalties.

4) Issue rules and regulations, legal interpretations, and corporate decisions governing investments, lending, and other practices.

Sources: OCC, CapTech AML Experience

What is it?

• Charters, regulates, and supervises all national banks and federal savings associations as well as federal branches and agencies of foreign banks.

• The OCC is an independent bureau of the U.S. Department of the Treasury.


1. Operate in a safe and sound manner.

2. Provide fair access to financial services.

3. Treat customers fairly.

4. Comply with applicable laws and regulations.

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Governance

Governance Overview: Federal Reserve

“The Fed” was created by Congress to provide the nation with a safer, more flexible, and more stable monetary and financial system.


What is it?

• The Federal Reserve (Also known as “the Fed”, “FRB”) was created on December 23rd, 1913.

• Conducting the nation’s monetary policy by influencing money and credit conditions in the economy in pursuit of full employment and stable prices.

• Supervising and regulating FIs to ensure the safety and soundness of the nation’s banking and financial system and to protect the credit rights of consumers.

• Maintaining stability of the financial system and containing systemic risk that may arise in financial markets.

• Providing certain financial services to the U.S. government, U.S. financial institutions, and foreign official institutions, and playing a major role in operating and overseeing the nation's payments systems.


1. Meet certain requirements and abide by certain standards outlined by the Federal Reserve to be able to borrow money from and process money through the Federal Reserve.

2. Systemically Important Financial Institutions (SIFI) must perform annual stress tests to prove stability and ability to return money to shareholders.

3. Note: The Federal Reserve can work with the OCC by governing and regulating FIs.

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https://www.fincen.gov/resources/statutes-regulations/usa-patriot-act


Governance

Governance Overview: Office of Foreign Assets Control (OFAC)

There is no prepackaged OFAC compliance program that fits the needs of every bank. Banks, obviously, range in size from small tosome of the largest institutions in the world. OFAC recommends utilizing its website and materials to ensure that the program a

financial institution designs upholds the OFAC regulations and is appropriate for the size and scope of the financial institution.

Sources: US Treasury - OFAC, CapTech AML Experience

What is it?

• Established in 1950, The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals

• Sanctions are administered through OFAC Sanctions and Specially Designated Nationals (SDN) Lists which target foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States

• OFAC Regulations & Sanctions must be followed by: (a) Any individual, wherever located, who is a citizen or resident of the United States;(b) Any person within the United States as defined in § 515.330;(c) Any corporation, partnership, association, or other organization organized under the laws of the United States or of any State, territory, possession, or district of the United States; and(d) Any corporation, partnership, association, or other organization, wherever organized or doing business, that is owned or controlled by persons specified in paragraphs (a) or (c) of this section.


1. There is no single compliance program suitable for every financial institution. OFAC is not itself a bank regulator; its basic requirement is that financial institutions not violate the laws that it administers.

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Governance

Major consequences for non-compliance to AML Regulation

1. Riggs Bank – Transaction Monitoring Failures following 9/111. $25 million dollar fine for failing to monitor suspicious financial transactions after 9/11, leading to the eventual sale of the bank. (Source: NY

Times)

2. JP Morgan Chase – Bernie Madoff Ponzi scheme• $1.7 billion fine for failure to maintain an effective AML Program with regards to Bernie Madoff multi-billion dollar Ponzi scheme. (Source:

Compliance Week)

3. BNP Paribas – Inability to screen transactions against US OFAC Sanctions List• $8.9 billion fine for illegal process of financial transactions subject to U.S. Sanctions (Source: Justice.gov)

4. HSBC – Drug Cartel Money Laundering• $1.9 billion fine for money laundering from drug cartels in Mexico and Colombia, which included placing Mexico in its lowest AML risk category

and doing extensive business there. (Source: Reuters)

1. Union Bank of California – Drug Money Laundering• $31 million dollar fine in total for failing to maintain an effective AML Program related to an elaborate drug money laundering scheme.

(Source: Forbes.com)

Sources: Links above, CapTech AML Experience

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http://www.nytimes.com/2004/07/19/us/at-riggs-bank-a-tangled-path-led-to-scandal.html?_r=0

https://www.complianceweek.com/blogs/enforcement-action/jpmorgan-pays-17b-for-failed-aml-compliance-that-aided-madoff

https://www.justice.gov/opa/pr/bnp-paribas-agrees-plead-guilty-and-pay-89-billion-illegally-processing-financial

http://www.reuters.com/article/us-hsbc-probe-idUSBRE8BA05M20121211

https://www.forbes.com/forbes/welcome/?toURL=https://www.forbes.com/2007/09/17/banking-money_laundering-biz-wall-cz_nv_0917laundering.html&refURL=https://www.google.com/&referrer=https://www.google.com/

AML Execution


Governance

AML Execution Overview

How is Anti-Money Laundering Executed?

• The US Federal Government and International Legislative Bodies rely on Financial Institutions to comply with various AML laws tocombat Money Laundering through the execution of AML programs.

What do Financial Institutions do?

• According to the Bank Secrecy Act and amended by the USA Patriot Act, Financial Institutions need to ensure they have organized an AML Program that completes the following:

1. A system of internal controls to ensure ongoing compliance.

2. Independent testing of BSA/AML compliance.

3. Designate an individual or individuals responsible for managing BSA compliance (BSA compliance officer).

4. Training for appropriate personnel.

5. A Customer Identification Program must be included as part of the BSA/AML compliance program.

• Note: All financial institutions must have an AML program in place for execution, but the roles and responsibilities and the process may differ based on size of the bank and the types of clients and AML risks that are present.

AML Regulation (BSA, Patriot Act, FFIEC Laws etc.)

AML Government Oversight (OCC, OFAC, FINCEN, Federal Reserve etc.)

Financial Institutions (Capital One, Wells Fargo etc.)

Customers (Individual Customers and Legal Entities)

High level AML regulatory structure:

Sources: FFIEC BSA Exam Manual, CapTech AML Experience

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https://www.ffiec.gov/bsa_aml_infobase/pages_manual/manual_online.htm


Governance

How the BSA 5 Components of an AML Program are Implemented by a Financial Institution

ID BSA 5 components of an AML Program How is this completed?

1 A system of policies, procedures and controls to ensure AML compliance Regulatory relations and reqs. controls mapping, Policy & Procedural controls

2 Independent testing of BSA/AML compliance. Creation of Audit and Testing Groups Independent from AML Program

3 Designate a BSA compliance officer Designation of a Chief AML Officer (CAMLO)

4 Training for appropriate personnel. Development of enterprise wide and localized AML training

5 In addition, a Customer Identification Program (CIP) Implementation of a Know Your Customer Program, which includes a CIP

Credit Card Auto LoansHome LoansBank / Small Business

List Screening Transaction MonitoringEnhanced Due DiligenceCustomer Risk Rating

Anti-Money Laundering Program3rd LOD

Independent Audit

Compliance Program1 2

3 4 51

2

4 5

4 5


BSA Execution Structure:

4 5

4 5

4 5

4 5

4 5

4 5

2nd LOD

1st LOD


Governance

Customers

Individual Customer: An individual person who applies for an account with the FI

Legal Entity Customer: A legal entity customer who applies for an account with the FI

TPPP: Third Party Payment Processor (ex. Venmo)

NBFI: Non-Banking Financial Institution (ex. Insurance Company)

PEP: Politically exposed person who is the customer, is/was related or associated to a PEP (ex. Prime Minister of England in 1984, his family or associates applying for applying for an Individual or Entity account).

MSB: Money Service Business (ex. Western Union or Moneygram)

NGO: Non-Government Organization (ex. Boy Scouts of America)

Fund: Collective term for mutual funds, hedge funds, and other forms of investment vehicles that manage pools of capital on behalf of investors.

Trust: Legal arrangement where one party (trustor or guarantor) transfers ownership of assets to a person or bank to be held or used for the benefit of others.

ATM: Automated Teller Machine (Organization) – Some ATMs are part of larger sales organizations and other ATMs are owned by the proprietor of the land or building where it is located.

AML Terms You Should Be Familiar With

Source: ACAMS, CapTech AML Experience

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Governance

AML Terms You Should Be Familiar With, continued

Source: ACAMS, CapTech AML Experience

Other

Bearer Shares: Negotiable instruments that accord ownership in a corporation to the person who is in physical possession of the bearer share certificate.

Correspondent Bank: Provision of banking services from one bank (Correspondent Bank) to another (Respondent Bank) (ex. ABC Bank providing services (wire transfers, cash management etc.)

Doing Business As: An entity that provides their “Doing Business As” name

North American Industry Classification Codes (NAICS): Classification system for businesses by industry, and for AML purposes to understand risk associated with that customer based on their industry

Standard Industry Classification (SIC): Original classification system for business by industry, released in 1937, but supplanted by NAICS codes in 1997. SIC is still used sparingly.

Offshore Bank: Though licensed to conduct banking activities, an offshore bank is prohibited from doing business with local citizens or in local currency as a condition of its license.

Payable Through Account: Transaction account opened at a depository institution by a foreign financial institution through which the foreign institution’s customers engage, either directly or through sub-accounts, in banking activities and transactions in the country where the account was opened.

Wolfsberg Group: Named after the castle in Switzerland where its first working session was held, the Wolfsberg Group is an association of global financial institutions who have developed global anti-money laundering guidelines for international private banks.

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Related Parties

Power of Attorneys – An attorney that has control over the account for a legally incapacitated person• All KYC Data must be collected on accounts that have a Power of Attorney associated with that account

Beneficial Owners – Beneficial Owners are individuals, group of individuals or entities that have direct or indirect power to vote or influence the transaction decisions on the account

• Usually BOs are defined as having 25% or more ownership over the equity interests of the customer• FIs have flexibility to define this further (i.e. can define BO strategy with less % ownership – ex. 10% or more ownership)• KYC CIP data must be collected on Beneficial Owners (ex. A partial owner of a company with a corporate Card account)

Account Controllers – Individuals who have the authority to execute transactions on the account( KYC CIP data must be collected on Account Controllers (ex. A parent/guardian of a child’s checking account))


Governance

Know Your Customer: Step 1 – Data Collection

Step 1: Collection of KYC Data on new Customers at Onboarding (1st / 2nd LOD)• Collection: As required by BSA/AML regulation, Financial Institutions must collect KYC information at onboarding for both Individuals

Customers (ex. Mike Shockey) and Legal Entity Customers (ex. Mike’s Margaritas).

• Sources: Data can be collected directly from the customer, derived from other sources within the Financial Institution, or from 3rd party sources (ex. Lexis Nexis).

• Retention: According to the BSA, the Financial Institution must retain KYC data for at least 5 years after the account is closed.


Data Element Individual Customer Legal Entity CustomerCIP (Customer Identification Program), examples include the following:

Name NameDate of Birth Physical AddressPhysical AddressTIN Number (ex. TIN, SSN) TIN Number

CDD (Customer Due Diligence), examples include the following:

Occupation & Annual Income Annual RevenueCustomer Contact Information Customer Contact InformationProduct(s) being applied for NAICS CodeNegative News (Y/N) on the customer Beneficial Ownership %Account Controllers (Y/N) Beneficial Owners, Account Controllers CIPAccount Controllers CIP

ACDD (Add’l Customer Due Diligence) , examples include the following:

PEP Information based on verification detailed later PEP Information based on verification detailed later

ATM LocationNGO Source of fundsMSB Destination of fundsTPPP information

KYC Data – CIP, CDD, ACDD Overview Table

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https://www.cov.com/-/media/files/corporate/publications/2016/05/fincen_releases_final_rule_on_beneficial_ownership_and_risk_based_customer_due_diligence.pdf


Governance

Know Your Customer: Step 2 – Verification of KYC Data


Step 2: Verification of KYC Data (1st LOD):• Verification: During onboarding, the 1st Line of Defense must verify the data to ensure the customer is who they say they are, after the customer

provides verification information/documentation based on CIP requirements collected.

• Documentary Verification:

• Individuals: For individual customers, unexpired government issued documentation needs to be provided. Ex. Drivers License, Passport, State ID, Military ID, Alien Registration card or other identifying documentation, the FI then verifies the identity of the customer.

• Entities: For entity customers, documentation showing the existence of the entity must be provided. Ex. Certified Articles of Incorporation, Government Issued Business License, Partnership Agreement, Trust Instrument, the FI then verifies the identity of the customer.

• Non-Documentary Verification: If the customer cannot provide documentation, the FI verifies the identity of the customer using their Name, TIN and other CIP data through a Credit Bureau Report, references with other Financial Institutions (314a/b), contacting the customer directly.

• 314(a) – a means for Financial Institutions and Law Enforcement to share information

• 314(b) – a means for Financial Institutions and their peers to share information

• Substantive Discrepancies: Anything that is discrepant between what the customer provides and the verification that is conducted, needs to be reconciled with the customer prior to the completion of onboarding.

• Ex. A customer provides a physical address in Wilmington, DE using his drivers license as part of his CIP data at onboarding for a Credit Card at ABC Bank. After verification using the customer’s driver’s license, ABC Bank notices that his physical address is listed in Philadelphia, PA. ABC Bank reaches out to the customer to understand the substantive discrepancy, and the customer responds saying he recently moved to Wilmington, DE, and provides some form of documentation to prove this.

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https://www.cov.com/-/media/files/corporate/publications/2016/05/fincen_releases_final_rule_on_beneficial_ownership_and_risk_based_customer_due_diligence.pdf


Governance

Know Your Customer: Step 3 – List Screening and ACDD-PEP Data Collection

Step 3: List Screening to ensure the Customer is not on any sanctioned lists (2nd LOD - LSO)• Screening: During the course of onboarding, the 1st LOD / 2nd LOD must also screen against the following lists to ensure the customer doesn’t have any

additional AML risk associated with them, and based on screening, can close the account based on what is found.

• OFAC Sanctions List - According to the BSA, “economic and trade sanctions based on U.S. foreign policy and national security goals against targeted individuals and entities such as foreign countries, regimes, terrorists, international narcotics traffickers, and those engaged in certain activities such as the proliferation of weapons of mass destruction or transnational organized crime.”

• OFAC Specially Designated Nationals List (SDN List) - According to Treasury.gov, “a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers...”

• Prohibited/Restricted Customer List (Hotlist) - A list of customers the Financial Institution designates that can no longer open an account due to previous interaction, or general unwanted ML risk.

• Negative News - Using a 3rd party search engine tool (ex. Lexis Nexis), an FI can understand any negative news associated with the account, according to Lexis Nexis, such as arrest, assault, bankruptcy, corruption, etc.

• Foreign PEP List - A foreign politically exposed person is deemed as a high risk customer due to the higher ML risk associated with that potential customer based on the ability for corruption or bribery due to their position.

• ACDD-PEP Data Collection – If the Customer (Individual Customer or Legal Entity) is or is related to a PEP, the following data elements must be collected:

Sources: BSA, Treasury.gov, LexisNexis, CapTech AML Experience

Data Element Individual Customer Legal Entity CustomerACDD (Add’l Customer Due Diligence), examples include the following:

Is the customer a Politically Exposed Person (PEP), or related to a PEP?

How is the PEP associated to the account?PEP Name

PEP NamePEP Position PEP PositionHow is the PEP associated to the account?

KYC Data - PEP Overview Table:

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Governance

Know Your Customer: Step 4 – Customer Risk Rating and EDD Data Collection

Sources: FINRA, Protivity AML Guide, CapTech AML Experience

Data Element Individual Customer Legal Entity CustomerEDD (Enhanced Due Diligence Data), examples include the following:

Source of wealth information Source of wealth informationAnticipated use of account Anticipated use of account

Nature of BusinessSite visits (Y/N)

EDD Data Overview Table:

Step 4: Customer Risk Rating to understand the customer’s AML risk (2nd LOD - CRR)• Risk Rating: After onboarding, the 2nd Line of Defense Customer Risk Rating team rates the customer as Low, Medium or High Risk.

• If the 2nd LOD Customer Risk Rating team realizes that a customer that is onboarded is high risk based on the CIP, CDD and ACDD data collected at onboarding, additional data must be collected on that customer, termed as “EDD” data.

• Drivers of Risk:

• Individual Customers: Occupation (Horticulture Grower), Physical Address (South Texas), Employment (Self-Employed).

• Entity Customers: NAICS Code (Casino), Geographic Location of Business (Mexico).

• Individual and Entity Customers: Negative Media (ML or illegal activity in the past), PEP Status, Products (Mortgage vs. Checking).

• EDD Data Collection: The 1st / 2nd LOD works to collect the Enhanced Due Diligence data to ensure the Financial Institution fully understands the risk associated with the High Risk Customer (ex. customer with a high risk Industry NAICS code i.e. MarijuanaDistributor).

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Governance

Know Your Customer: Step 5 – Financial Intelligence Unit (FIU) & InvestigationsEnhanced Due Diligence (EDD) & Transaction Monitoring (TMO)

Content Sources: FINRA, Protivity AML Guide, CapTech AML Experience; Image Source: http://irregulartimes.com/wp-content/uploads/2013/05/SpitzerSAR.jpg

Step 5: Financial Intelligence Unit and Investigations:Enhanced Due Diligence (EDD) Investigators

• Responsibilities: EDD is in charge of ongoing investigations for High-Risk customers for the Financial Institution, as well as ensuring that adequate review of high risk customers occurs at onboarding, after EDD data is collected by the LOB.

Transaction Monitoring (TMO) Investigators

• Responsibilities – Another key part of investigating and monitoring the customers is the transaction monitoring group which ensures that accounts have appropriate transactional activity (ex. No ACHs (Direct Deposits from an employer) entering an account for a customer that is unemployed.

• KYC Data Refresh – The TMO & EDD groups also have the ability to request a refresh of the customer’s data, by sending a message to the 1st Line of Defense (LOD) to reach out to the customer for additional information from them (ex. TMO requesting an updated Employment Status from the customer, based on the ACHs entering their account)

• Government reporting capabilities – TMO & EDD can file SARs with FinCEN

A Suspicious Activity Report (SAR) is a report that U.S. financial institutions are required to file with FinCEN for insider abuse by an employee, violations of law >$5,000 and a subject can be identified, violations of law >$25,000 and a subject cannot be identified, transactions >$5,000 that could be involved in ML or when a customer is known to be operating as an unlicensed MSB (Money Service Business).

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https://en.wikipedia.org/wiki/FinCEN


Governance

Business Analysis is a Critical Part of Success for AML Implementations

Business Analysts can support Financial Institution’s AML Programs by being able to:

• Master new concepts quickly

• Be flexible by performing in multiple roles

• Build relationships with new points of contact in multiple areas within an AML organization

Content Sources: CapTech AML Experience, IIBA

“Business Analysis is the practice of enabling change in an organizational context, by defining needs and recommending solutions that deliver value to stakeholders.”

– International Institute of Business Analysts

Potential Business Analyst roles on an AML project:

• Requirements Engineering and Development

• Process Improvement and Management

• Testing Execution and Analysis

• Training Creation and Support

• Reporting Development

• Data Analysis and Synthesis

• Product Management and Monitoring

• Audit Support

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Governance

Our experiences of Business Analysis on AML Projects

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AML Initiated KYC Refresh Process• Requirements Definition support of a new process for updating customer information for top 10 US Bank

AML Investigations Training• Learning and comprehending AML Regulations and Consent Order Action Plans to create training guidance/documentation and facilitate training

of 300+ investigators to investigate 16,000+ alerts

KYC Requirements Management• Requirements Definition support for Standard and Procedural documents. Development of procedures defining data elements to be collected

and refreshed for all customers across the FI Lines of Business (ex. Name, D.O.B)

CTR System Replacement and Process Improvement• Comprehension of a new workflow management tool and requirements definition of desired workflow processes. Training on new tool and

business processes with a focus on change management and issue resolution during go-live

Testing & Audit Validation Analysis and Support• Supporting definition of testing and validation scope, execution and analysis of remediation to ensure successful AML implementation

KYC Commercial Remediation• Responsible for issue resolution and production oversight for 23 LOBs that were remediating 300,000+ customers. Key focus areas include

process review and redesign, communication and change management, business analysis of common issues and bottlenecks

“As a BA, when considering your company’s products and services, put yourself in the place of the customer. What do you like, what don’t you like? You too are a stakeholder and what you think is

important. If you see an issue, don’t be afraid to speak up” –International Institute of Business Analysts

Content Sources: CapTech AML Experience, IIBA


Governance

Additional Resources

Visit the FFIEC BSA/AML Exam Manual website.

• http://www.ffiec.gov/bsa_aml_infobase/pages_manual/manual_online.htm

Read more about Money Laundering and AML strategy on Protiviti AML Guide.

• https://www.protiviti.com/US-en/insights/guide-us-anti-money-laundering-requirements-faq-6th-ed

Learn about other ways of Money Laundering and AML strategy through new Block-Chain Technology.

• https://globalanticorruptionblog.com/2016/11/07/the-road-ahead-in-anti-money-laundering-aml-can-blockchain-technology-turn-the-tide/

Research about AML Certification with the Association of Certified Anti Money Laundering Specialists (CAMS).

• http://www.acams.org/earn-the-aml-certification-gold-standard/

Content Sources: CapTech AML Experience

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http://www.ffiec.gov/bsa_aml_infobase/pages_manual/manual_online.htm

https://www.protiviti.com/US-en/insights/guide-us-anti-money-laundering-requirements-faq-6th-ed

https://globalanticorruptionblog.com/2016/11/07/the-road-ahead-in-anti-money-laundering-aml-can-blockchain-technology-turn-the-tide/

http://www.acams.org/earn-the-aml-certification-gold-standard/

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Thanks for Attending!

Questions?

Appendix


Governance

Examples of Money Laundering – Drug Trafficking

“Rick” launched his own drug trafficking operation using funds from a cartel he once worked for. With the help of former drug colleagues he used several methods to launder drug proceeds:

• Cash shipments arrived by boat or plane and were promptly placed by couriers into a range bank accounts (Smurfing).

• What phase of ML does this represent?

• An agent then would have the funds moved to the personal accounts of overseas intermediaries, each of whom arranged to transfer the funds back into the country into accounts at the national central bank, which granted authorization.

• Rick would call the intermediary and cancel the transfer and then withdraw the cash and wire it back in country to other accounts using the authorization from the central bank for legitimacy and to obfuscate the trail of funds.


• After completing these transfers, Rick, with the assistance of lawyers, bank managers, and other professionals, would purchase real estate. He offered unusually high commission rates to sweeten the deal and gain commitment (3-5%). These purchases were usually made in the names of other individuals or companies.


• Other Money Laundering examples:

Source: Egmont Group

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Governance

Examples of Money Laundering – Black Market Peso Exchange Example

Additional Information:PBS – Frontline Episode: Black Market Peso ExchangePBS – Frontline Episode: Drug Special Source: OAG.gov

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http://www.pbs.org/wgbh/pages/frontline/shows/drugs/special/blackpeso.html

http://www.pbs.org/wgbh/pages/frontline/shows/drugs/special/us.html

https://vimeo.com/131253630

https://oag.ca.gov/sites/all/files/agweb/images/toc/fig26.jpg


Governance

Examples of Money Laundering Cont’d. – Hawala

Informal value transfer systems that are often associated with ethnic groups from Africa or Asia, and commonly involve the international transfer of value outside the legitimate regulated banking system – [Based on trust]

Appeal to Money Launderers & Terrorists:

• Proliferation of AML measures worldwide makes Hawala one of the lone areas that still exists without supervision in some jurisdictions.

• Not subject to formal government oversight and do not keep detailed records in standard form.

• Leaves little or no paper trail when moving funds.

• Details about the customer receiving the funds are scarce and usually just the two Hawala brokers are aware of this information.

• Can be used at any phase of the Money Laundering Cycle due to it being a remittance system.

Sources: WSJ, ACAMS, CapTech AML Experience

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Governance

A Picture is Worth a Thousand Words…or maybe $$$?

Source: ACAMS

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Governance

Governance Overview: Federal Financial Institutions Examinations Council (FFIEC)

• What is it?

• Established on March 10, 1979, the Council is a formal interagency body empowered to prescribe uniform principles, standards, and report forms for the federal examination of financial institutions by the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the Consumer Financial Protection Bureau (CFPB) and to make recommendations to promote uniformity in the supervision of financial institutions.


• The Council is responsible for developing uniform reporting systems for federally supervised financial institutions, their holding companies, and the nonfinancial institution subsidiaries of those institutions and holding companies. It conducts schools for examiners employed by the five federal member agencies represented on the Council and makes those schools available to employees of state agencies that supervise financial institutions.

• Link to the FFIEC Bank Secrecy Act Exam Manual: https://www.ffiec.gov/bsa_aml_infobase/pages_manual/manual_online.htm

FFIEC is responsible for “promoting the uniformity and consistency in the supervision of financial institutions.”

Sources: FFIEC, CapTech AML Experience

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http://www.ffiec.gov/exam/default.htm



Governance

Governance Overview: Financial Action Task Force (FATF)

Sources: FATF, CapTech AML Experience

The FATF is therefore a “policy-making body” which works to generate the necessary political will to bring about national legislative and regulatory reforms in the areas of Money Laundering, Terrorist Financing & WMDs.

• What is it?

• The objectives of the FATF are to set standards and promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system. Starting with its own members, the FATF monitors countries' progress in implementing the FATF Recommendations, reviews money laundering and terrorist financing techniques and counter-measures, and promotes the adoption and implementation of the FATF Recommendations globally.

• Developed a set of Recommendations that considered the “gold standard” in combatting money laundering and the financing of terrorism and proliferation of WMDs. First issued in 1990, the FATF Recommendations were revised in 1996, 2001, 2003 and most recently in 2012 to ensure that they remain up to date and relevant, and they are intended to be of universal application.


• FATF members are expected to abide by the Recommendations and thus have a trickle down effect to the member countries to the financial institutions that are domiciled or do business in those countries.

• Much of the ML/TF policies and legislation in FATF participating countries are leveraged from the FATF Recommendations.

• For more info on the FATF, visit their website here: http://www.fatf-gafi.org/about/membersandobservers/.

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http://www.fatf-gafi.org/about/membersandobservers/


Governance

FINRA (Financial Industry Regulatory Authority)

•FINRA is dedicated to investor protection and market integrity through effective and efficient regulation of broker-dealers.

•FINRA is not part of the government. We’re an independent, not-for-profit organization authorized by Congress to protect America’s investors by making sure the broker-dealer industry operates fairly and honestly.

FinCEN (Financial Crimes Enforcement Network)

•FinCEN is a bureau of the U.S. Department of the Treasury. The Director of FinCEN is appointed by the Secretary of the Treasury and reports to the Treasury Under Secretary for Terrorism and Financial Intelligence.

•FinCEN’s mission is to safeguard the financial system from illicit use and combat money laundering and promote national security through the collection, analysis, and dissemination of financial intelligence and strategic use of financial authorities

Basel Committee

•The Basel Committee on Banking Supervision (BCBS) is the primary global standard setter for the prudential regulation of banks and provides a forum for cooperation on banking supervisory matters. Its mandate is to strengthen the regulation, supervision and practices of banks worldwide with the purpose of enhancing financial stability

Egmont Group

•Created in 1995 as an informal organization by several national FIUs. Name was derived from the meeting location of the inaugural meeting in Brussels

•Goal of the group is to provide a forum for FIUs to improve support to their national AML programs and to develop protocols for sharing information

Wolfsberg Group

•The Wolfsberg Group is an association of thirteen global banks which aims to develop frameworks and guidance for the management of financial crime risks, particularly with respect to Know Your Customer, Anti-Money Laundering and Counter Terrorist Financing policies.

•The Group came together in 2000, at the Château Wolfsberg in north-eastern Switzerland

EU Directives for Prevention of ML/TF

•Requires EU memeber states to achieved specified results in combatting and preventing ML/TF

•4 Directives have been published (1991, 2001, 2005, 2015) –With each directive becoming more stringent and expansive in an effort to keep up with the trends inML/TF and the technological changes in banking/finance

Other U.S. and International AML Government Agencies You Should Be Familiar With

Sources: FINRA, Wolfsberg, ACAMS, Basel, FinCEN, CapTech AML Experience

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Governance

BSA Components 1-4: Controls, Testing, CAMLO, Training

1) Controls

• Regulatory Relations - To ensure Financial Institutions are compliant with AML Regulation, Compliance can create a team to interact with governing agencies to ensure compliance.

• Policy and Procedural Controls – Controls for creation and management of policy and procedures to ensure consistent rigor is applied across all AML documentation within the FI, such as a corporate policy repository with controls around the documents stored there.

• Control requirements database – Some Financial Institutions AML Programs have also implemented control databases where regulatory requirements are documented and directly tied to controls that are in place within the 1st, 2nd and 3rd lines of defense.

2) Independent Testing

• Independent Audit and Testing groups – To provide a necessary “separation of powers” so that folks not within the AML Program can perform testing and provide those independent results to the AML Program, Independent Audit and Independent Testing groups are created outside of the AML Program.

3) Chief AML Compliance Officer

• BSA Compliance Officer – Designation occurs within the AML Program itself, and he/she oversees the program as a whole and offers perspective and decision making on direction of AML programs, and is usually an individual (individuals) with years of ML experience.

• Ex. Ensures an FI is adhering to Anti-Money Laundering regulation and governing bodies, the CAMLO is responsible for the dedicated AML governance structure, policy and procedural maintenance, training and third party audit, as well as regulatory relations with various federal and international AML agencies.

4) Training

• AML Training – Ensures a consistent approach to AML is taken for the FI, and is required of all associates. AML Program can create an enterprise wide training, whereas the unique and localized areas can create their own specific trainings as well.

Sources: Protivity AML Guide, FFIEC BSA Exam Manual, CapTech AML Experience

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Governance

BSA Component 5: Know Your Customer Program

5) Know Your Customer (KYC) Program• What is it?

• According to Protiviti AML Guide, KYC generally refers to the steps taken by a financial institution to:• Establish the identity of a customer;• Understand the nature of a customer’s activities;• Assess the money laundering and terrorist financing risks associated with that customer.

• Note: Not every Financial Institution’s KYC program is the same, as interpretation of the AML laws needs to be understood and uniquely applied to their product and service offering. Also, banks adhere to Federal requirements, expectations and prevailing practices to differing degrees.

• What happens?

1. Customer Identification (CIP) – According to the FFIEC BSA exam manual, “The CIP is intended to enable the bank to form a reasonable belief that it knows the true identity of each customer. The CIP must include account opening procedures that specify the identifying information that will be obtained from each customer. It must also include reasonable and practical risk-based procedures for verifying the identity of each customer.”

2. Customer Due Diligence (CDD) – According to the FFIEC BSA exam manual, “Detecting and reporting unusual or suspicious transactions that potentially expose the bank to financial loss, increased expenses, or reputational risk; avoiding criminal exposure from persons who use or attempt to use the bank’s products and services for illicit purposes; and adhering to safe and sound banking practices.”

3. Enhanced Due Diligence (EDD) – According to the FFIEC BSA exam manual, “for higher-risk customers is especially critical in understanding their anticipated transactions and implementing a suspicious activity monitoring system that reduces the bank’s reputation, compliance, and transaction risks.”

Sources: Protivity AML Guide, FFIEC BSA Exam Manual

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Governance

KYC Individual Customer Example

1. Application: Ward Wood walks into an ABC Bank branch to open a credit card account (Card LOB).

2. KYC Step 1 – KYC Data Collection: The bank teller gives him paperwork to provide his CIP and CDD data.

a. Credit Check: A BAU credit check will occur to understand credit risk associated to Ward.

3. KYC Step 2 – Verification: During or after credit check, Documentary / Non Documentary verification is performed on Ward to ensure he is who he says he is.

4. KYC Step 3 – List Screening: After credit check and verification is performed with no issues, List Screening is performed to see if Ward is on any designated OFAC, SDN etc. lists.

a. Foreign PEP screening reveals that Ward has a relationship to the Prime Minister of a foreign country (South Korea), so LSO reaches out to the 1st LOD to request ACDD – PEP and EDD data on him (all Foreign PEPs are high risk customers).

5. KYC Step 4 – Customer Risk Rating: After List Screening, Customer Risk Rating is performed on Ward.

a. Ward is flagged as a high risk customer due to his Foreign PEP relationship, and the 1st LOD should already have collected both ACDD-PEP and EDD data at this point due to LSO reaching out in Step 3.

6. KYC Step 5 – Enhanced Due Diligence: Using the CIP, CDD, ACDD-PEP and EDD information collected, the Financial Intelligence Unit in an ongoing manner investigates Ward to ensure his relationship with ABC Bank does not supersede the ML Risk threshold that WF wants to keep with its customers.

7. KYC Step 6 – Transaction Monitoring: The TMO unit in an ongoing manner monitors Ward’s credit transactions to ensure he is not engaging in any potential risky Money Laundering account activity.

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Governance

KYC Legal Entity Customer Example

1. Application: Mike Shockey walks into an ABC Bank branch to open a corporate checking account (Commercial Bank LOB) for his company “Shockey’s Shoes Emporium.”

2. KYC Step 1 – KYC Data Collection: The bank teller gives him paperwork to provide his company’s CIP and CDD data.

a. Credit Check: A BAU credit check will occur to understand credit risk associated to “Shockey’s Shoes Emporium.”

3. KYC Step 2 – Verification: During or after credit check, Documentary / Non Documentary verification is performed on “Shockey’s Shoes Emporium” to ensure the company is who Mike says they are (i.e. Articles of Incorporation, Gov’t Issued Business License).

4. KYC Step 3 – List Screening: After credit check and verification is performed with no issues, List Screening is performed to see if “Shockey’s Shoes Emporium” is on any designated OFAC, SDN etc. lists, as well as to understand if Mike or his company have any Negative News associated to them, or if Mike is or has been a PEP, or is related to or has been related to a PEP.

5. KYC Step 4 – Customer Risk Rating: After List Screening and no issues arise, Customer Risk Rating is performed on “Shockey’s Shoes Emporium.”

a. The Customer Risk Rating model rates “Shockey’s Shoes Emporium” as “High Risk” after it is found that his company operates in“High Risk” areas within the country, Laredo, TX, therefore the 1st LOD is notified and asked to collect EDD information from Mike.

6. KYC Step 5 – Enhanced Due Diligence: Using the CIP, CDD and EDD information collected, the Financial Intelligence Unit in an ongoing manner investigates “Shockey’s Shoes Emporium” to ensure his relationship with ABC Bank does not supersede the ML Risk threshold that ABC Bank wants to keep with its customers.

7. KYC Step 6 – Transaction Monitoring: The TMO unit in an ongoing manner monitors “Shockey’s Shoes Emporium” transactions to ensure he is not engaging in any potential risky Money Laundering account activity.

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Governance

Helpful Resources

FFIEC BSA/AML Exam Manual

• http://www.ffiec.gov/bsa_aml_infobase/pages_manual/manual_online.htm

FinCEN Website

• http://www.fincen.gov/

OFAC Website

• http://www.ustreas.gov/offices/enforcement/ofac/

Protivity AML Guide

• https://www.protiviti.com/US-en/insights/guide-us-anti-money-laundering-requirements-faq-6th-ed

Block-Chain Technology

• https://globalanticorruptionblog.com/2016/11/07/the-road-ahead-in-anti-money-laundering-aml-can-blockchain-technology-turn-the-tide/

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http://www.ffiec.gov/bsa_aml_infobase/pages_manual/manual_online.htm

http://www.fincen.gov/

http://www.ustreas.gov/offices/enforcement/ofac/

https://www.protiviti.com/US-en/insights/guide-us-anti-money-laundering-requirements-faq-6th-ed

https://globalanticorruptionblog.com/2016/11/07/the-road-ahead-in-anti-money-laundering-aml-can-blockchain-technology-turn-the-tide/

Documents

IIBA Charlotte Metro Chapter Meeting: CapTech AML … economy to give the ... WTU made several payments totaling $450,000 for “onsulting Services” to a fake ... Evolving Technologies