Blog Entries tagged 'AML Fraud and other things'

BALL OF CONFUSION (THAT'S WHAT THE WORLD IS TODAY)*

Byrne — Wed, 25 Jan 2012 01:00:00 +0100

Sorting out confusion by using sanctions as a tool for needed change

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The Temptations' most covered song* addressed a 1970 world of war, illegal drugs, and crooked politicians. (Remember "vote for me and I'll set you free?") Funny how we start 2012 with corruption, fear of Iran's nuclear programs, and a border country, Mexico, with rampant violence because of the extensive drug trade.

[...]

SOMETHING GOOD COMING�THERE HAS TO BE

Byrne — Thu, 05 Jan 2012 01:00:00 +0100

Here's how to work for a better 2012 in AML

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My last message in 2011 was for 2012 resolutions. As we begin this year, those resolutions need to be expanded to detailed strategic plans for AML professionals, whether individual plans or institution- or agency-wide goals. Now is the perfect opportunity to identify your mission; to establish timelines to complete any projected changes; and to set up measurements to ensure succ [...]

PRETZEL LOGIC AND YOU BETTER THINK TWICE: SONGS TO START A YEAR ON

Byrne — Fri, 09 Dec 2011 01:00:00 +0100

Random (but somehow connected) musings of 2011

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The close of 2011 seems more about what lies ahead for the AML community than what has transpired.

The road ahead for those of us in compliance, enforcement, or consulting will be long because of everything we have discussed all in this blog--expansion of AML obligations (sanctions, corruption, financial crime, etc.); hei [...]

�ALL TOGETHER NOW'

Byrne — Thu, 17 Nov 2011 01:00:00 +0100

The 23rd Annual ABA/ABA Money Laundering Enforcement Conference and other events this week

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The Beatles were not contemplating friends and colleagues getting together at the ABA/ABA, the original money laundering prevention conference, when they wrote this little ditty, but it is appropriate.

Being fortunate to have developed the id [...]

GRACELAND�FOR MUSIC FANS, TWO DIFFERENT MEANINGS

Byrne — Thu, 10 Nov 2011 01:00:00 +0100

Filing SARs--still different perspectives?

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I'm here in Johannesburg in the Republic of South Africa for our inaugural AML/CTF conference.

I was struck by the conference brochure description for one of our panels, "Best Practices for Creating Actionable STRs." (For our U.S. readers, STRS are "susp [...]

IT NEVER RAINS IN SOUTHERN CALIFORNIA: MAN, IT POURS

Byrne — Sun, 09 Oct 2011 01:00:00 +0100

Private-public partnership works best when enforcement is a last resort form of "feedback"

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I just returned from the 33rd Annual Regulatory Compliance Conference for the California Bankers Association. Who knew there was a compliance conference in the 1970s? (As a tribute, I have used the Albert Hammond song title as the name for this blog.)

This was the culmination of a busy period. During the pas [...]

'TEN YEARS AFTER,'* WHERE ARE WE?

Byrne — Thu, 15 Sep 2011 01:00:00 +0100

Lessons learned, and lessons that need to be learned

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I would never be so presumptuous as to think I could have a view of the ten years since 9/11 that would be dramatically different than others. Instead, it seems that simply reporting on some of the events in the past week that touch on this important memory makes the most sense.

By the way, the title of this bl [...]

DON'T WORRY, BE HAPPY*

Byrne — Thu, 25 Aug 2011 01:00:00 +0100

Perspectives from "Donnie Brasco," improving AML in the islands, and a very special opportunity

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A Caribbean island working hard to change perceptions

Bobby McFerrin's late 80s call to calm down is often seen as music reflecting the way of life in Caribbean cultures. But that is too simplistic.

Having just returned from Antigua for an AML and financial crime conference, it i [...]

HOT FUN (?) IN THE SUMMERTIME

Byrne — Wed, 03 Aug 2011 01:00:00 +0100

Beneficial ownership, prepaid access, and more AML issues to keep us busy

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I am sure that Sly and the Family Stone weren't focused on AML challenges when they released this late 1960s hit. Given the 100-plus degree temps in Washington, D.C. (and the continuous brutal heat in places like Dallas), it would be easy to focus only on the weather.

But we know AML takes no vacation. So what is keeping u [...]

SMURFS ARE BACK BUT IS CASH STILL THE PROPER FOCUS FOR AML?

Byrne — Tue, 19 Jul 2011 01:00:00 +0100

What's the best song with "blue" in the title?*

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For those of you with young children, you have probably heard them clamor to see the new Smurfs movie on July 29th. (Some of my kids, who are over 18, would rather see "Horrible Bosses," but that's a different conversation.)

Smurfs mean something quite different to th [...]

'WON'T GET FOOLED AGAIN': REGULATORY CRITICISM WILL HINDER PRIVATE-PUBLIC SECTOR SUCCESSES

Byrne — Tue, 28 Jun 2011 01:00:00 +0100

Human trafficking problem looms too large to allow wrong regulatory emphasis to hinder bank efforts

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I was prepared to answer the blog editor's call for an AML-focused report from ABA's recent Regulatory Compliance Conference--the 25th Anniversary, no less--and the continued commitment from the banking industry to stay focused on the many current and future compliance challenges facing these professionals. S [...]

CH-CH CHANGES: WHY ARE WE STILL FIXING THE SAME THINGS?

Byrne — Thu, 02 Jun 2011 01:00:00 +0100

Changes ("turn and face the strain") are needed

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As we approach mid-year of 2011, it is a common practice to assess where we are. Whether we are discussing a political term of office, a sports team's mid-season report, or in this case, where we are in the AML environment, a mid-year or mid-season assessment is more than an exercise. It is a time to stop, take a breath, and figure out if we need to correct our strat [...]

'WHAT'S GOING ON?': THE WORLD�AND BSA/AML�IN A POST-BIN LADEN CONTEXT

Byrne — Thu, 12 May 2011 01:00:00 +0100

Marking a milestone, and looking towards 9/11's tenth anniversary

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It is so hard to accept that it has almost been 10 years since 9/11.

Those of us in the AML community realize that the day changed all of society, with the loss of life, change in travel protocols, and our overall sense of fear. We also specifically saw a shift in financial laws, regulations, and policy. As I have noted many tim [...]

'CATCH ME IF YOU CAN': REWARDING CRIMINALS? OR LEARNING FROM EXPERTS?

Byrne — Thu, 21 Apr 2011 01:00:00 +0100

Make sure you're getting the freshest criminality

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It has always intrigued me on how we learn from mistakes, whether intentional (and thus not a mistake) or because of negligence or some other deficiency.

This quandary is top of mind with the recent Broadway production of "Catch Me if You Can," from the book and movie about the life of convicted criminal, Frank Abagnale, Jr. (Note: [...]

DON'T COME AROUND HERE NO MORE*

Byrne — Thu, 31 Mar 2011 01:00:00 +0100

What John Byrne heard in the halls at a recent meeting—and what it means for the industry

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AML Conference Hallway Conversation and a Proposal Everyone Opposes

At a recent conference, I was looking for the talk of the hallways. What I wanted to know was what was on everyone's mind as they were challenged by new products, resource limitations, politics, and the 21st century syndrome-people with the attention spa [...]

SOMETHING IN THE AIR*: OR, STARVE A RAT TODAY

Byrne — Thu, 03 Mar 2011 00:00:00 +0100

World turmoil brings AML's importance into crystal-clear focus

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The world's turmoil always has a financial angle.

While some have incorrectly suggested that anti-money-laundering issues are not nearly as important as virtually every other banking issues (Dodd-Frank et al), we know that compliance challenges remain. In fact, word is beginning to spread about a return to regulatory oversight tha [...]

WE'RE ALL LOOKING [AND] SOMETIMES WE FIND *

Byrne — Wed, 09 Feb 2011 00:00:00 +0100

Human trafficking and other AML/BSA challenges underscore need for teamwork

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Returning from yet another out-of-town AML program, it struck me that AML professionals, wherever they are located, have the same questions and challenges.

Whether from financial institutions in Puerto Rico (where the conference was located) or from entities in the Caribbean islands (where a number o [...]

IS ANYBODY LISTENING? *

Byrne — Thu, 20 Jan 2011 00:00:00 +0100

There has been, and will continue to be, a reply!

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Many of you think as I do—that the AML community is much more that a collection of professionals that handle compliance within their financial institutions or government agencies. Instead, we are members of the broader community in which we live. Never has that been clearer than now with the focus on the horrific crime of human trafficking.

&nb [...]

STUCK IN THE MIDDLE

Byrne — Fri, 07 Jan 2011 00:00:00 +0100

Three resolutions to take for a better AML/BSA year in 2011

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I saw an obituary this week of Scottish singer, Gerry Rafferty, who penned "Stuck in the Middle with You," an early 70's hit for Stealers Wheel. (Some of you may also remember the song from a 1990's Quentin Tarantino movie, "Reservoir Dogs [...]

D�J� VU*: WE HAVE ALL BEEN HERE BEFORE

Byrne — Wed, 01 Dec 2010 01:00:00 +0100

Where's the news in the embassy banking controversy?

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Forty years ago, CSNY (ask your parents)
released the album with the above title and dramatically changed rock.
Earlier this month, I could not help but wonder, while reading the
press accounts of banks exiting embassy accounts, "Haven't we all been
here before?"

The issue, for those new to BSA/AML, is that
several of [...]