AML

From MgmtWiki
Jump to: navigation, search

Full Title or Meme

Anti-Money Laundering Rules as established first in the US and then in international banking.

Context

Banks handle people's money with more or less discretion.

Taxonomy

  • AML/CFT = anti-money laundering and countering the financing of terrorism
  • Customer Due Diligence (CDD) Final Rule which seems to be an attempt to block some workarounds to AML. These are the goals of CDD:
  1. identify and verify the identity of customers,
  2. identify and verify the identity of the beneficial owners of companies opening accounts,
  3. understand the nature and purpose of customer relationships to develop customer risk profiles,
  4. conduct ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information.

Financial Institutions

The following institutions are recognized by the US Financial Crimes Enforcement Network (FinCEN) as needing to comply:

  • Casinos (betting parlors, sports book)
  • Depository Institutions (Banks, thrifts)
  • Insurance Industry (health, life, annuities, property, casualty)
  • Money Services Businesses (Transmittals, Pay Day Loans)
  • Mortgage Co/Broker (real-estate)
  • Precious Metals/Jewelry Industry (bars, coins, bling)
  • Securities and Futures (seems like blockchain has been added in here - think ICO = Initial Coin Offering)

Problems

Follow the money and you will find the crooks.

Solutions

  • FinCEN Issues Analysis of Identity-Related Suspicious Activity for 2021 issued on 2024-01-09
    Financial Trend Analysis (FTA) on information linked to identity-related suspicious activity in Bank Secrecy Act (BSA) reports filed in calendar year 2021. FinCEN’s analysis found that approximately 1.6 million reports (42% of the reports filed that year) related to identity—indicating $212 billion in suspicious activity. “This report reveals the existence of significant identity-related exploitations through a large variety of schemes,” said FinCEN Director Andrea Gacki. “Robust customer identity processes are foundational to the security of the U.S. financial system, and critical to the effectiveness of financial institutions’ programs to combat money laundering and counter the financing of terrorism. Financial institutions are encouraged to work across their internal departments to address these schemes.”
  • FinCEN Issues First National AML/CFT Priorities and Accompanying Statements 2021-06-30

References