| STANDING IN THE SHADOWS OF AML |
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Small players, as well as headline names, helped keep NYC incident from becoming a disaster. And that's often the case
* * * In 2002, there was a tremendous documentary on the musicians who provided the true excellence that was the "Motown" sound. The film, "Standing in the Shadows of Motown*," won several film and music awards, while putting some much needed light on these key partners of the singers and groups that received all of the accolades from that great time in ‘60s and ‘70s music history.
Of course, this made me think about the "players" in AML and counterterrorism field that frequently do not receive the recognition for the day-to-day assistance they provide to this effort.
While having well-known experts front and center is important in the ongoing battles to stem money laundering and terrorism, there were a few events recently that continue to make it clear that often it is the average person (average in role or position, not in value) who is key to proper vigilance and effective deterrence.
I just returned from San Francisco and the unique West Coast AML Forum (WCAML), where compliance professionals, auditors, regulators, and law enforcement officials gather with no media or vendor exhibitors and discuss essential AML-related topics. The limit to practitioners only is meant to encourage open and candid exchanges of ideas and techniques. [See the end of this article for a link to the annual ABA/ABA Money Laundering Enforcement Conference.]
While there are some nationally-known presenters such as Dennis Lormel and FinCEN's Tom Fleming, this annual event (now in its 18th year) really emphasizes the committed AML professionals in the private and public sector and how they engage in important endeavors. This includes such tasks as working with Suspicious Activity Review Teams; banking money service businesses in challenging times; and receiving updates in the form of law enforcement case studies. Since the WCAML prohibits media coverage, I will refrain from reporting on specifics, except to say that the regular AML professional provides as much value to our need for understanding current themes and best practices as the national expert. I cannot recall the number of times that government participants thanked the AML officials present from the private sector and vice versa for their vigilance in simply doing what was right.
A perspective on the New York plot The recent terrorist attempt in New York City's Times Square also brings home the value of ordinary vigilance on the part of everyone as opposed to relying solely on expensive technologies for monitoring or information gathering.
While, unfortunately, political finger-pointing is occurring after the successful prevention of yet another attempted attack, some in government avoided the blame game and recognized the assistance of citizens simply trying to do the right thing.
For example, John S. Pistole, FBI Deputy Director, told the press that several federal agencies and the NYC Police Department worked together (for a change) and stopped what would have been a horrific act. Pistole added that everyday citizens were instrumental in this effort too:
"Prevention will continue to be our end-game. And we offer thanks to vigilant citizens, like the vendors in Times Square who first noticed this suspicious vehicle. This investigation, like others we have handled in the past year, once again reminds us that our work is not finished. And we will continue to work side by side with our partners-and with citizens across the country-to find and stop those who would do us harm."
So, what does this teach us" Where do we go from here? The AML community must continue to work together, and while there is nothing yet that we have learned from Times Square that points to a financial transaction (the terrorist did buy his car with cash but does not appear to have been to a bank to make that withdrawal), we must watch the evidence from this case to determine what we can add to our red flags or other warning signs.
(Note: I can say that at WCAML there was a session that did acknowledge the role that reviewing media reports plays in due diligence.)
In addition, recognizing AML assistance at all levels and commending employees for their efforts should be a priority for senior corporate management and high-ranking government officials. This gets at the "tone at the top" issue.
Motown would have been just a word without the musicians, and AML is not a community without the dedicated men and women who try to do the right thing.
* For you real music fans, the documentary contains a number of current singers reprising the hits from that decade, including a version of "What Becomes of the Broken Hearted," by Joan Osbourne, that will blow you away if you have a pulse.
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or post them below. HELPFUL LINKS: 2010 American Bankers Association/American Bar Association Money Laundering Enforcement Conference: This longtime favorite of the compliance fraternity returns in 2010 with a new, up-to-the-minute program, live, in the nation's capital. The conference is set for Oct. 17-19 at the Washington Marriot Wardman Park Hotel, Washington, D.C. For further information, click here. Set as favorite Bookmark
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