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Interagency Statement on Sharing BSA Resources and Challenges

12/7/2018

Photo Credit: semisatch

On October 3, 2018, an Interagency Statement was issued by five agencies/regulatory bodies to provide banks with an option to enter into a collaborative arrangement involving two or more banks to share their available resources in order to ensure compliance with Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) requirements.

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Are You Gambling with Your BSA Program?

6/27/2017

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Photo Credit: Vitaliy Kytayko

Akash Govil, Manager

It’s that time of the year again for your BSA/AML compliance audit. We know how much you enjoy it when your BSA internal auditors show up with smiles as big and long as their request memos and sample sizes – from policies to procedures, risk assessments to training logs, CTRs to SARs, CIPs to EDDs, and “SMHs” to “OMGs”… Alright, let’s face it, compliance doesn’t exactly scream excitement. There’s a ton of activity to stay on top of and many mundane compliance tasks which all financial institutions dedicate their blood, sweat, and tears to (okay, maybe not blood).

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The Case of Foreign Banks and Heightened Scrutiny

3/24/2017

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Photo Credit: Kheng Ho Toh

There is what appears to be a trend happening in the foreign branch banking market that seems all too consistent. That trend is the influx of MRAs, MOUs, and Consent Orders being handed down by the federal regulators for having insufficient BSA/AML and OFAC compliance programs. It’s not much of a surprise seeing there have been various high-profile cases of banks facilitating and abetting money laundering and terrorist financing.

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De-Risking of Foreign Correspondent Banks

1/24/2017

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Photo Credit: Michael Borgers

On October 5, 2016, the Office of Comptroller of Currency (“OCC”) issued guidance relative to foreign financial institutions de-risking policies with respect to maintaining foreign correspondent banking relationships. The guidance comes after heavy scrutiny of the U.S. foreign correspondent banking sector, which provides cross-border commerce with many foreign financial institutions in jurisdictions with weakening AML and CFT provisions.

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Interagency Statement on Sharing BSA Resources and Challenges

Are You Gambling with Your BSA Program?

The Case of Foreign Banks and Heightened Scrutiny

De-Risking of Foreign Correspondent Banks

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