The Three Lines of Defense Model has gained popularity as the de facto model for organizing governance, risk management and internal control roles and responsibilities since the Institute of Internal Auditors (IIA) published “The Three Lines of Defense in Effective Risk Management and Control,” position paper in 2013. The IIA recently announced that they would embark on a key project to refresh and update this document.
AML and Financial Crime
Insights and guidance from ACA's team of experienced compliance and technology professionals.
Analytical segmentation modeling (ASM) is one way to design an effective AML monitoring strategy through the development of a quality model to achieve segmentation. ASM involves combining customer or bank accounts with similar properties and transaction behavior to make it easy for banks to formulate risk signals based on their various classes of customers. This model sets threshold levels for the segments monitored by identifying patterns based on the groups of similar customers and/or accounts.
Technology is an essential weapon for financial services firms in the battle against anti-money laundering (AML). The Office of the Comptroller of the Currency (OCC) issued a joint statement with other regulators earlier this month encouraging financial institutions to try new and innovative ways of combating AML. Three types of technology – advanced analytics, software robots, and artificial intelligence (AI) – could help make it easier to detect and prevent money laundering, as well as comply with existing regulations and follow the guidance of this joint statement.
While the financial institutions have the desire to improve the data quality and availability, data governance is often driven by external regulations to implement a program to ensure requirements outlined in DFS Part 504 regulation are met.
The US Office of the Comptroller of the Currency (OCC) has indicated that it will be focusing on the effectiveness of anti-money laundering (AML) systems and controls after including the topic on its list of FY 2019 annual priorities. For OCC-regulated banks, this means exams will concentrate on how up-to-date AML and Bank Secrecy Act (BSA) programs are with evolving threats and new rules.
On May 11, 2018, broker-dealers and other financial institutions currently covered by the US Anti-Money Laundering (AML) regime will need to become compliant with FinCEN’s new customer due diligence (CDD) requirements.
Due to the nature of its business, trade finance is considered a high-risk product that is frequently used by individuals and criminal organizations to launder funds, conduct terrorist financing, and evade the sanctions, regulations, and restrictions of the Office of Foreign Assets Control ("OFAC
Link or network analysis can help the compliance risk industry better analyze data sets to discover alarming patterns. This form of analysis allows compliance teams to dive into massive piles of valuable information and process data much faster than holistic methods can.
Trying to get ahead but feel like you’re falling behind? The “most wonderful time of the year” can quickly turn into the most stressful time of the year when you’re caught between closing out year-end projects while strategizing and planning for the New Year.
In May 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued its final rule on beneficial ownership with respect to customer due diligence ("CDD") requirements.
Financial institutions (“FI’s”) are required by Anti-Money Laundering (“AML”) regulations to perform risk-based due diligence for their customers and prospective customer. This due diligence is referred to as Customer Due Diligence (“CDD”).