Sometimes risk analysis can result in paralysis. Finding your risk tolerance and applying it to specific situations requires a nuanced approach. I am always wary of anyone who tells me categorical rules – e.g. we do not do business in Russia because it is too risky. In this era of oversimplification, such statements border on intellectual dishonesty. A careful approach to risk analysis always involves...
Webinar: 2016 Year in Review: AML and Sanctions Enforcement Tuesday, January 19, 2016, 12 Noon EST Sign Up Here The Justice Department and the Treasury Department’s Office of Foreign Asset Control had another strong year in AML and Sanctions enforcement. With ever-changing sanctions programs, and vigilant AML enforcement, businesses now face significant risks of civil and criminal enforcement. Sanctions enforcement has stretched beyond financial institutions...
Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting about anti-money laundering (AML), terrorism financing and CCO certifications. Lauren’s profile is here, and she can be reached at [email protected]. Preventing money from getting to terrorists is a chief goal of AML programs. But at a basic level an AML program is only as strong as its budget, regardless of...
Just when you thought things could not get any weirder, along comes the New York Department of Financial Services and proposes a new regulation that sets forth minimum requirements for anti-money laundering transaction monitoring systems and sanctions watch list filtering. The regulations include an annual requirement that the Chief Compliance Officer at New York banks and money transmitters certifies that the bank’s or money transmitter’s...
FinCEN is an active law enforcement agency. They have taken on more responsibility over the last five years for AML enforcement, and they show no signs of letting up. FinCEN’s proposal to expand beneficial ownership requirements for financial institutions is expected to be released before the end of the year. FinCEN’s proposal in this area will have a significant impact on companies subject to AML...
Anti-money laundering compliance is a very difficult task. The number of risks is exponential. AML compliance officers have an innovative and rich history of compliance techniques and strategies. In the end, AML compliance depends on: accurate and comprehensive risk assessments; pre-screening of customers through appropriate KYC programs; and audit and monitoring of transaction and customer activity. Despite the commitment and dedication of AML compliance professionals,...
Webinar: August 18, 2015 1 PM to 2 PM EST Sign Up Here Companies are spending more resources on ethics and compliance programs. Department of Justice and SEC prosecutors are increasing their focus on compliance training programs to make sure they are tailored to a company’s risk profile and the company’s workforce. Compliance officers have to develop training content that is engaging and relevant to...
Volkov Law TV announces new subscription options and pricing for on-demand Webinars. We know our scheduled webinars do not always fit your busy schedule: Learn What You Want, When You Want It! Volkov Law TV Here We now offer pricing for individual webinars and have reduced our subscription fees. In addition, we offer Flexible Enterprise Rates for companies and organizations if needed. Individual Webinars are...
AML compliance reminds me of a classic Three Stooges scene from A Plumbing We Will Go (view episode here) – Curly, as one of the plumbers, continues to add pipes to a leaking bathtub, only to be surprised when the water continues to come out of the end of the pipe, and so on — you will get the picture. We all know about the...
FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML compliance. In March 2015, FinCEN imposed a $10 million penalty on Trump Taj Mahal in Atlantic City, New Jersey, for violations of the Bank Secrecy Act (BSA). In addition to this hefty...
