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		<title>&quot;Tear Down Those Walls!&quot;: Bring together AML/BSA now</title>
		<description>Comments for &quot;Tear Down Those Walls!&quot;: Bring together AML/BSA now at http://www.ababj.com , comment 0 to 3 out of 3 comments</description>
		<link>http://www.ababj.com</link>
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			<title>Investigator</title>
			<link>http://www.ababj.com/briefing/tear-down-those-walls-bring-together-aml-bsa-now-2.html#pc_586</link>
			<description>Good article. In essence, it will be the federel regulators and not the financial institutions that drive convergence. It is a fact that AML Examiners have now begun to ask how a financial institution handles SAR filings for a fraud unit that works as a siloed function.

I agree with the authors that there is psychological schism between the a SAR investigator and the traditional Fraud investigator, but it will have to be overcome. While operational solutions can be invoked to consolidate operations, I do not currently see a single software solution. Programs that monitor suspicious transactions are essential, but they do not yet pick up some observations that can be made only by a human, such as an underwriter noticing information that he knows is not true or a delivery person delivering financed equipment to a suspicious address. 

I'm convinced that convergence will become a reality. It is better to get on board now than try to jump on an already moving train. - John</description>
			<pubDate>Fri, 15 Oct 2010 12:53:05 +0100</pubDate>
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			<title>Fraud and Risk Manager</title>
			<link>http://www.ababj.com/briefing/tear-down-those-walls-bring-together-aml-bsa-now-2.html#pc_487</link>
			<description>The main difference between fraud and AML investigators boils down to this.  Fraud investigators must find the fraud or the bank may suffer loss.  The AML investigator needs to find suspicious activity that may be money laundering and file a report with FinCen.  In AML wheather you find it or not as long as a process is in place the Bank is not exposed to penalty.  From here you fall into silo's (AML v Fraud) of expertise.  They do not blend.  If you step into the software providers space AML vendors do not have a good track record at building fraud solutions.  If they don't get fraud neither will the AML investigator.  Additionally here is another reason why I want the 2 separate.  If I have an alert that hits as a fraud alert and AML  then I'm lilkely to be prohibited from contacting the customer due to &quot;tipping&quot;.  Keeping the two disciplines separate gives me options - Texas</description>
			<pubDate>Thu, 03 Jun 2010 12:32:55 +0100</pubDate>
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			<title>Director, Global Fraud Prevention, WWM</title>
			<link>http://www.ababj.com/briefing/tear-down-those-walls-bring-together-aml-bsa-now-2.html#pc_286</link>
			<description>Thanks for your recent article. The industry analyst have predicted that the incidents of fraud and financial crime will continue to increase. What better way to consolidate resources for meeting regulatory requirements and boosting the bottom line profitability. Seems to me it is worth the organizational challenges. - Ellen Joyner-Roberson</description>
			<pubDate>Tue, 16 Feb 2010 10:07:31 +0100</pubDate>
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