Although there are political signals that our current administration will provide financial institutions regulatory enforcement relief in comparison to years prior, this is not the case. As evidenced by the consistent penalties enforced over the past several years, AML/BSA regulatory enforcement remains a top priority. Examples include severe civil monetary penalties now being issued to mid-size and small financial institutions, jurisdictions imposing mandatory certification programs for compliance personnel, and compliance violations resulting in civil prosecution and debarment for compliance executives.
Insights and guidance from ACA's team of experienced compliance and technology professionals.
More and more, regulators are examining AML and terrorist financing monitoring software solutions to see if they are tuned correctly; and citing financial institutions who fail to meet the regulatory standards. One issue for both regulators and these institutions is the creation of excessive volumes of “false positive” activity alerts, or alerts on activity that after evaluation, is not determined to be suspicious.
FINRA recently issued Regulation Notice 19-18 (the “Notice”), which provided guidance to member firms regarding their monitoring obligations with respect to suspicious activity pursuant to the Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) requirements.
On April 18, the Financial Crimes Enforcement Network (FinCEN) announced that they have imposed their first-ever penalty on a peer-to-peer cryptocurrency exchange for violating AML regulations, among other violations.
Every anti-money laundering (AML) program should be reviewed periodically to confirm that the program is performing efficiently and effectively. Analytics can play a big role in this review by providing new insights that support evidence-based decision-making.
ACA Telavance is delighted to moderate a panel at the The Institute of Internal Auditors (IIA), New York Chapter Annual Audit Conference. Dan Collins, Managing Director, will lead a discussion about regulatory expectations for internal audit of BSA/AML and sanctions, including:
Michael Held, Executive Vice President of the Legal Group at the Federal Reserve Bank of New York, spoke at the 1LoD Summit in New York on April 2, 2019.
When it comes to anti-money laundering (AML) transaction monitoring, financial services firms are under more pressure than ever to prove that the approach they are taking is working. Regulators want to see obvious evidence that firms are generating the right level of suspicious activity reports (SARs) for their size, geography, and business types, usually in the form of statistics and reporting. In turn, boards and senior management teams are now demanding to see this same information to be sure the firm is meeting its compliance obligations. As a result, AML transaction monitoring analytics are in more demand than ever before.
Press coverage this week picked up a story about the Financial Conduct Authority (“FCA”) warning UK hedge fund managers of imminent spot checks on their financial crime controls.
We are excited to speak at the FIBA AML Compliance Conference on March 13th. Uday Gulvadi, Director of Internal Audit and Risk, will join a panel to discuss his thoughts on the Beneficial Ownership Rule.
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.