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An A to Z Look at Suspicious Activity Reporting
Your Back-to-School Refresher Course - SAR 101
By Lori Moore, CRCM, Director of Compliance
The backpacks are stuffed, the buses are on the road again, and students are in the classroom. Back-to-school is in full swing for elementary through university students, but what about the students of Bank Secrecy Act (BSA) compliance? Who are they? They should be anyone who works in a financial institution, and based on the discussion generated from our June story, Current Hot Spots in BSA/AML Compliance, they have lots of questions. In particular is concern that regulators most frequently cite financial institutions for failing to adequately identify, monitor and report suspicious activity. To help your institution avoid such a citing, we’re responding to your requests for additional information on how to more adequately and effectively handle suspicious activity reporting. Whether you’re the professor (aka the Compliance Officer) who could use a concise yet comprehensive training document, or you’re the student (aka everyone else) who needs a handy how-to sheet for daily use, this A to Z SAR refresher is for you. Developed with the help of Ledra Finley, ATTUS’ Senior BSA/AML Compliance Consultant, it provides a step-by-step guide to improving the effectiveness of your Suspicious Activity Reports (SARs).


BSA/AML - Wire Transfers: Record-Keeping, Retention, Retrievability and Risk

BSA/AML compliance requires strong risk assessment and control over activities that can be associated with money laundering. But, managing these checks and balances can be an overwhelming task. This webinar focuses on the record-keeping, retention, and the retrievability requirements for fund transfers set forth under the Bank Secrecy Act. We also look at how those same requirements can be used as a tool in your AML program to manage the risks by helping you spot red flags that may indicate potential money laundering.
Speaker:
Lori Moore, CRCM
Director of Compliance
ATTUS Technologies
9/28/2011 3:00PM to 4:00PM ET

Question: Why are accounts for non-governmental organizations and charities high-risk?
Answer: The flow of funds into and out of these types of accounts can be complex and are therefore, susceptible to abuse by money launderers and terrorists. For example, large dollar donations can be given anonymously, making the source of funds difficult to track. In addition, charitable organizations are typically designed to serve the needs and/or interests of certain groups, communities and/or causes so the legitimacy of the transactions can also be difficult to ascertain. Guidelines have been issued by the U.S. Treasury to assist charities in adopting practices to reduce the risk of terrorist financing or abuse, which can also serve as a reference to financial institutions in the effort to mitigate and manage the related risk.
For more information check out: Anti-Terrorist Financing Guidelines: Voluntary Best Practices for U.S.-Based Charities, September 2006.
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.

Account Takeover: Secret Scams
Online Weaknesses Aren't Only Links that Lead to Fraud
Online fraud is getting quite a bit of attention these days, as it relates to incidents of so-called account takeover, typically the result of phishing attacks waged against retail and commercial bank accounts.
But in the larger picture of account takeovers, is the focus on online fraud giving banking institutions an accurate picture of fraud? Phil Blank, with Javelin Strategy & Research's Security, Risk and Fraud Practice, says many incidents of account takeover are actually perpetuated via relatively low-tech means, not phishing.
"The No. 1 takeover in 2010 was change of physical address, and adding a new registered user fell to second place," Blank says. "It doesn't surprise me that if you make the assumption that many account takeovers are done through things like man-in-the-browser attacks, that as more technology to mitigate man-in-the-browser attacks is out there, those takeovers would go down. ... But what banks need to be aware of is that much of this fraud is occurring on the consumer and business-customer side, and most won't invest in technology that catches these attacks."
Getting Tough with Cybercriminals
Obama Administration Seeks Tougher Penalties for Hackers
Eric Chabrow, GovInfoSecurity.com
In testimony before the Senate Judiciary Committee September 7, Associate Deputy Attorney General James Baker outlined an administration legislative initiative, first unveiled in May, to increase the maximum penalties for cybercrimes. "Such modifications are appropriate in light of the scale and scope of our nation's current cybercrime problem," Baker said.
One of the reasons the administration seeks tougher penalties for hackers is the changing nature of illicit cyber intrusions. "Where 10 years ago hackers were more commonly motivated by curiosity or seeking notoriety, most criminal hackers today are motivated by greed," Baker said. "Federal law needs to more effectively deter this spreading criminality."

Stopping the Mid-Career Crisis
Why Some Professionals Experience Crises in Their Transitions
Athena Vongalis-Macrow, HBR.org
Many professionals seek new opportunities through career change in order to meet personal goals and to increase the likelihood of advancement. And, changing one's career is also closely associated with renewed career commitment and job satisfaction. So why are some professionals likely to experience their mid-career transition as a mid-career crisis? Leadership intervention — or lack thereof — is to blame.
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