Robust Customer Identity Verification Serves More Than Compliance Obligations
Blocking Fraud, Money Laundering, Identity Theft and Other Financial Crimes at Your Front Door
By Lori Moore, CRCM, Director of Compliance

Many a generation has felt the truth of Charles Dickens’ eloquent words “It was the best of times; it was the worst of times.” Despite the ripe old age of 153 years, those words have striking relevance in today’s modern world. At present, it is the best of times in that the internet has made it possible for all to more easily connect with other people from around the world, to access information from sources previously out of reach and to obtain services that in the past were limited to brick and mortar. Yet, it is also the worst of times as white collar, organized and cyber criminals are taking great advantage of that expansive access to perpetrate internet-based crimes and to more easily gather the information needed to carry out traditional crimes. All of which is driving up crime rates, in particular financial crimes.     
 




OFAC 101: Does Your Company Play By The Rules?

Complying with OFAC is more complex than ever before. Do you have a comprehensive understanding of the term "OFAC Compliance" and how it impacts your industry? Attend this webinar and learn more about the history of OFAC since September 11, the responsibilities you have as a company to comply with OFAC regulations, and how you can avoid expensive penalties and fines as a result of OFAC violations. 

Speaker: 

Lori Moore, CRCM 
Director of Compliance
ATTUS Technologies

3/29/2011 3:00PM to 4:00PM ET





Question: Should we be doing an OFAC check on the banks every day?  Should we be doing an OFAC check on our customer?

Answer:  
Unfortunately, I cannot give you a definitive answer as it is really a risk-based decision for each institution. Most financial institutions (FI) do check all parties to a wire transaction using a single lookup. However, the process regarding each (sender, banks, beneficiary), depends largely upon your overall OFAC compliance program.  

With respect to your customers, the decision to check or not with each wire transfer is typically dependent upon how often your institution scans your entire database. Do you perform an OFAC scrub each time it is updated or do you only scan on a predetermined periodic basis such as monthly or quarterly? If you compare your entire customer base immediately after each update and do not wait, the likelihood of missing a potential match on a wire is greatly reduced if you choose not to scan each time. If your institution does not conduct a scan immediately following an update, the window is wider and your risk of violations is increased.  

As for banks, again, I would apply the logic of whether or not to scan the same FI multiple times if it has already been scanned in a single day. But, make sure your scan includes the beneficiary bank (whether domestic or foreign) and when applicable, any intermediary banks.   

Got a question on a tricky regulation? We want to hear from you.  Submit your question and an expert will answer it in a future issue.



AML Security Heightened
Upheaval in Libya, Egypt, Spurs FinCEN Alerts
Tracy Kitten, BankInfoSecurity.com

On Feb. 24, the Treasury's Financial Crimes Enforcement Network recommended U.S. financial institutions closely monitor accounts held by foreign political figures in Libya.

On Feb. 16, a similar precautionary bulletin was issued for transactions involving political figures from Egypt. FinCEN identified misappropriated assets, illegal payments and public corruption proceeds as the top three concerns.

These alerts hammer home the point that recent global unrest calls for financial institutions to turn up the heat on their own anti-money laundering practices.

FinCEN: BSA Rule Reorganization Effective Now
Reorganization became effective March 1st 
News Now, CUNA.org

As expected, the Financial Crimes Enforcement Network's (FinCEN) streamlined reorganization of its Bank Secrecy Act (BSA) rules became effective March 1.

As part of the reorganization, FinCEN transferred its BSA regulations into a new Chapter X of Title 31 of the Code of Federal Regulations (CFR).

The reorganization split the regulations "into general and industry-specific parts, ensuring that a financial institution can identify its obligations under the BSA in a more organized and understandable manner." However, FinCEN has emphasized that it "has not made any substantive changes to the BSA rules."



Six Ways to Avoid Being a Micro Manager
Recognizing the definitional & situational challenges
Kevin Eikenberry, KevinEikenberry.com

Think about your perfect supervisor/manager/leader for a minute. Build a mental list of the attributes that perfect person would possess and think about the words you would use to describe that person.

Done?

I don’t know what is on your list, but I’d bet the farm on what isn’t.

Micro manager.

I’ve never met anyone who wanted a micro manager for a boss.

Yet I’ve met many who felt they had a supervisor who was a micro manager, and I’ve met many leaders who struggle with that characteristic – knowing that they don’t want to be seen as one. I also know – for the most part – people who are seen as micro managers are acting with good intentions.