BoA a silver lining in damning ‘FinCEN Files’ report; Wells Fargo CEO puts foot in mouth
Bank of America gets a pat on the back for going beyond an “observe and report” approach to filing a SAR, and we learned this week that Wells Fargo’s CEO needs a little unconscious bias training.
‘FinCEN Files’ show Europe’s AML efforts maybe aren’t so world class
The damning revelations from the “FinCEN Files” leaks have once again put Europe and its supposed world-leading anti-money laundering rules under the spotlight.
Westpac set to pay record $912.6M civil penalty for AML failures
Westpac is bracing for a record AUS$1.3 billion (U.S. $912.6 million) civil penalty issued by Australia’s financial crime regulator related to a money-laundering scandal and the facilitation of child exploitation in the Philippines and Southeast Asia.
‘FinCEN Files’ fallout: Where do banks go from here?
The “FinCEN Files” report raises the question: What should banks be doing to address the trillions of dollars’ worth of banking transactions that are facilitating criminal activity every year?
FinCEN leaks impart key lessons on basics of writing SARs
Martin Woods, who has analyzed many of the suspicious activity reports released as part of the “FinCEN Files,” offers best practices for compliance officers in writing SARs.
‘FinCEN Files’ highlight bank leadership flaws, not compliance flaws
Compliance has been taking some heat in the wake of the “FinCEN Files” reports, but it’s banks’ senior leadership that failed, not the folks filing all those SARs.
FinCEN leaks damage trust between banks and regulators, but serve higher purpose
The “FinCEN Files” leaks divided opinions within the community of financial crime compliance officers. Trust has been damaged, writes Martin Woods, but these leaks could facilitate real reform.
‘FinCEN Files’ report casts compliance officers in unfair light
The BuzzFeed “FinCEN Files” investigation purportedly uncovered evidence of a catastrophic, international collapse of internal controls within the world banking system. But that argument is misleading, to the point of being disingenuous.
Swedbank being investigated for suspected market abuse
Swedbank announced the Swedish Financial Supervisory Authority has opened an investigation into the bank for potential violations of the regulation on market abuse in connection to the disclosure of suspected money laundering.
Recent OCC case shows widespread liability when a BSA program fails
Who faces liability when a Bank Secrecy Act program is deemed to be deficient? A series of recent enforcement actions taken by the OCC against individuals at a now-defunct New Jersey bank provides a case study.
FinCEN seeking comment on AML program overhaul
The Financial Crimes Enforcement Network has proposed a plan to issue AML guidance every two years to encourage financial institutions to align their Bank Secrecy Act compliance programs with the agency’s enforcement priorities.
Gut instinct keeps humans ahead of AI in fight against financial crime
As artificial intelligence evolves and takes on new tasks, whether it can develop the instinct of an experienced compliance professional will be key to its prevalence in the AML world, writes Martin Woods.
Forget the status quo: Proactive AML is the path forward
The AML community is guilty of tolerating the failing status quo, and very few have dared to confront, challenge, and disrupt the inefficient and ineffective practices. A proactive approach could be the solution, writes Martin Woods.
Best practices KYC: What to do when your client is in the headlines
How do we, as AML professionals, assess negative media alerts? It should start with a conversation with the client relationship manager, but it shouldn’t end there, writes Martin Woods.
FCA proposes expanding scope of financial crime reporting obligations
The U.K. Financial Conduct Authority seeks comment on a new proposal that would widen the scope of its annual financial crime reporting obligations to include firms whose regulated activities potentially pose a higher money laundering risk.
We’re losing the war on AML, and big consultancies aren’t helping
Financial crimes expert Martin Woods writes that, in his experience, the big consultancy firms have made a substantial negative contribution to global AML endeavors.
Banking regs reemphasize rules for monitoring accounts of foreign officials
Five federal regulatory agencies issued a reminder to banks and financial institutions that they should continually monitor risks associated with the accounts of foreign officials.
Hat tip to HSBC for stopping money laundering, saving lives
If you’re in search of proof that what you do matters, look no further than the AML efforts of HSBC in preventing $500 million from reaching the bank accounts of criminals, writes Martin Woods.
Federal banking regs clarify BSA/AML compliance violation response
Two strikes and you’re out, say four federal agencies to repeat violators of Bank Secrecy Act/anti-money laundering compliance requirements.
Basel Committee issues final AML risk management guidance
The Basel Committee on Banking Supervision recently issued an updated version of its guidelines on sound management of risks related to anti-money laundering and combating the financing of terrorism.
Interactive Brokers to pay $38M for SAR, AML failures
Interactive Brokers has agreed to pay $38 million in settlements with three regulatory agencies related to anti-money laundering lapses, including repeated failures regarding the filing of suspicious activity reports.
SFO confiscates $7M from ex-Afren execs in fraud case
The U.K. Serious Fraud Office announced it has secured orders confiscating £5.45 million (U.S. $7 million) from two former executives of oil and gas exploration company Afren.
ICA, Mongolian Compliance Association launch bespoke qualification
The International Compliance Association announced a partnership with the Mongolia Compliance Association to offer a bespoke e-learning program to 12 professional associations and their 10,000-plus members in compliance-related roles.
SARs overload slowing efforts to combat financial crime
For the global AML community, there is a need to recognize too much valuable time is spent filing too many low-value suspicious activity reports that will never become the subject of any law enforcement action, writes Martin Woods.
Commerzbank fine demonstrates danger of AML lapses
The Financial Conduct Authority’s fine of £37.8 million (U.S. $47.5 million) on Commerzbank’s London branch is a reminder that the most fundamental risk-based AML controls are still not being implemented at some financial services firms.
Analysis: When clean money is used for dirty purposes
There are times when it is a necessary to consider where clean money is going to as much as where dirty money may have come from, writes financial crime expert Martin Woods.
ICA, AMPEC partner on Mexico expansion
The International Compliance Association announced a partnership with the Mexican Association of Ethics and Compliance Professionals to offer the ICA’s full suite of accredited qualifications in Mexico.
Analysis: Following the telephone trail to detect fraudsters
One way to thwart money launderers is to take a page from the government’s playbook and examine smartphone applications when the contamination of fraud or money laundering is discovered.
Managing emerging trade-based money laundering risks
Trade-based money laundering was already happening prior to the coronavirus pandemic, but now its nature has shifted. The ICA offers key considerations for managing emerging risks.
Mexico’s war on corruption an uphill battle for compliance officers
Companies doing business in Mexico face an uphill battle with their anti-corruption compliance efforts as the country’s government struggles to control—and, in many cases, contributes to—its endemic corruption problem.
Following $107M fine for lax controls, SEB shares AML efforts
Sweden’s financial watchdog was fined SEB $107 million for weak governance practices related to the bank’s anti-money laundering controls in its Baltics subsidiaries.
Analysis: Learning to learn from our mistakes with AML
Scientists and doctors cannot succeed or make medical breakthroughs without being prepared to fail. The same approach should be taken to combating anti-money laundering, writes financial crime expert Martin Woods.
FCA fines Commerzbank London $47.4M for AML failures
Commerzbank London will pay a £37.8 million (U.S. $47.4 million) penalty in a settlement with the U.K. Financial Conduct Authority for anti-money laundering systems and controls failures.
Analysis: Path to effective AML is doing less with more
The answer to being more effective at stopping money launderers is to challenge the value of processes that are clearly failing. Financial crime expert Martin Woods explains.
Analysis: Let Westpac’s missteps be a cautionary tale
By balking at original allegations, Westpac opened itself to infinitely more harm, writes financial crime expert Martin Woods.
Danske faces criminal complaint over market abuse violations
Denmark’s financial regulator has filed a criminal complaint against Danske Bank for violating market abuse regulations concerning inadequate market monitoring and opposite trades.
A country-by-country analysis of anti-corruption efforts in Latin America
CCOs looking to navigate the fluid corruption risk environment in Latin America will want to review a newly released report on how countries are uncovering, punishing, and deterring corruption—particularly now, amid a pandemic.
Analysis: Don’t ignore financial misconduct in ‘plane’ view
Compliance officers must let go of the fear that often accompanies respect for big money (or luxurious aircrafts) and hold the difficult conversations when ferreting out bad actors, writes financial crime expert Martin Woods.
Europol launches new financial and economic crime body
Europol has created the new European Financial and Economic Crime Center, with the aim of enhancing operational support to EU member states and EU bodies in the fields of financial and economic crime.
Westpac outlines compliance failures that led to AML breaches
An internal report outlining compliance failures by Australia-based financial institution Westpac that led to 23 million breaches of the country’s AML/CTF laws concluded “a mix of technology and human error” were to blame.
How to scour your organization for pandemic fraud risks
“Only when the tide goes out do you discover who’s been swimming naked,” said Warren Buffett. With the pandemic tide out, here are some related frauds that are likely already occurring that corporations should be watching for.
Analysis: When a bonus becomes less incentive, and more compromise
Financial crime expert Martin Woods explores what happens when the annual bonus causes employees to disregard their values for want of a dollar.
Investigation into EY’s audit of Danske Bank dropped
Denmark’s state prosecutor has dropped its investigation into whether Big Four firm EY violated anti-money laundering laws in connection with its audit of Danske Bank.
Westpac announces more executive changes amid investigation
Amid a money-laundering investigation and faced with allegations of facilitating child exploitation in the Philippines and Southeast Asia, Westpac has appointed a new head of financial crime compliance.
Analysis: Fraud in Germany propels new European AML plan
Financial crime expert Martin Woods reviews the “cum-ex” scandal and how a recent action plan from the European Banking Authority aims to help stop such schemes from burgeoning.
EC unveils six-point plan to tackle money laundering
The European Commission’s new six-point plan highlights what measures the agency will take to enforce, supervise, and coordinate EU rules on combating money laundering and terrorist financing.
Justice Department to recover more than $49M involving 1MDB
The Department of Justice reached a settlement to recover more than $49 million in assets associated with the international money laundering and bribery scheme involving Malaysia’s state development fund 1MDB.
Cyber-criminals have supply chains, too
All cyber-attacks leave a trail. These trails can be complex, of course, but the criminals cannot avoid them. Thus, they leave a supply chain of intelligence and data.
Lesson from Westpac: If you can’t do the simple things correctly, watch out
If a bank or a firm cannot execute on the simple things, such as cash transaction reporting, there is little reason to be confident of compliance in other more complex and challenging areas.
Bank Hapoalim’s bad day: $904M in tax evasion, FIFA fines
Israel’s largest bank and its Swiss subsidiary will pay a total of $904 million in separate DOJ settlements related to (1) a massive tax-evasion scheme and (2) its role in a money-laundering conspiracy with FIFA.