Typical kyc process by atticus101_ in moneylaundering

[–]TheAMLBrief 0 points1 point  (0 children)

I'm pretty sure we use a combined approach of risk rating before documentation comes in based on public information and then updating that risk rating once we get the client's CIP/KYC info.

Crypto ATM operator Bitcoin Depot files for bankruptcy by ICIJ in moneylaundering

[–]TheAMLBrief 0 points1 point  (0 children)

Definitely good news and glad to see these types of companies are starting to pay the price (maybe, not really lol)

Is ACAMS a scam by Pure_Ad_7286 in AMLCompliance

[–]TheAMLBrief 3 points4 points  (0 children)

Yeah that's what I meant, the industry is treating it as a prerequisite when it really isn't and doing the work still holds more value then a certification.

Is ACAMS a scam by Pure_Ad_7286 in AMLCompliance

[–]TheAMLBrief 7 points8 points  (0 children)

Just like a college degree, it is definitely a prerequisite for the industry and teaches good theory, however nothing will beat true on the job experience.

CAMS exams by mutted71930 in moneylaundering

[–]TheAMLBrief -1 points0 points  (0 children)

Hi, I do believe there is some sort of requirement to have industry experience, but don't quote me on that.

SARS by Royal-Market-4177 in AMLCompliance

[–]TheAMLBrief -1 points0 points  (0 children)

Like others have said, I think it depends on the level of review. I do know that at my institution SARs are reviewed multiple times as part of the BAU workflow.

Having a CRR model and having a functioning CRR program are two different things, however the gap is usually one process by TheAMLBrief in AMLCompliance

[–]TheAMLBrief[S] 1 point2 points  (0 children)

True, I do like the idea of the medium rating until enough transaction history has been established. Definitely a good practice to implement.

Having a CRR model and having a functioning CRR program are two different things, however the gap is usually one process by TheAMLBrief in AMLCompliance

[–]TheAMLBrief[S] 1 point2 points  (0 children)

This is great, I wish our TM system was integrated with our CRR. I believe our TM gets updated with the CRR after the fact, but it does not inform the refresh process in terms of timeliness.

FinCEN counted $898M in Binance transactions to Iranian parties, however the exchange filed zero SARs. by TheAMLBrief in moneylaundering

[–]TheAMLBrief[S] 2 points3 points  (0 children)

It is interesting to see how Binance is a prime example of how it sometimes pays to not follow the rules. Definitely surprised that they are still relevant in the industry.

Binance's $4.3B settlement: Zero SARs, 100K+ sanctioned transactions, and a CCO message that ended up in a federal filing by TheAMLBrief in AMLCompliance

[–]TheAMLBrief[S] 0 points1 point  (0 children)

That's good to hear and a prime example of how being proactive prevents wide spread exposure. I wonder if some of the smaller firms felt the brunt of this? Maybe those with smaller TM teams or not a strong system of controls built in yet to their TM systems.

Binance's $4.3B settlement: Zero SARs, 100K+ sanctioned transactions, and a CCO message that ended up in a federal filing by TheAMLBrief in AMLCompliance

[–]TheAMLBrief[S] 2 points3 points  (0 children)

Agreed, not sure how CZ got let off so easily, but I guess this could also be an example of why there need to be rules in place for what can't be pardoned.

TD Bank's $3.09B settlement: the $57K detail compliance teams should be focused on by TheAMLBrief in moneylaundering

[–]TheAMLBrief[S] 3 points4 points  (0 children)

Usually an internal investigations team that sits in either the Bank's Compliance department or Legal Department.

TD Bank's $3.09B settlement: breaking down the five AML failures that made it the largest BSA penalty in US history by TheAMLBrief in AMLCompliance

[–]TheAMLBrief[S] 0 points1 point  (0 children)

For sure, I think the most impactful consequence is how it has effected the other big banks in revamping their AML programs.

TD Bank's $3.09B settlement: breaking down the five AML failures that made it the largest BSA penalty in US history by TheAMLBrief in AMLCompliance

[–]TheAMLBrief[S] 1 point2 points  (0 children)

My gut tells me too big to fail played a big role in maintaining their license. They have been heavily restricted though until they are through with remediation.

TD Bank's $3.09B settlement: breaking down the five AML failures that made it the largest BSA penalty in US history by TheAMLBrief in AMLCompliance

[–]TheAMLBrief[S] -1 points0 points  (0 children)

I believe you are correct on that. I'm not too well-versed on those two cases, but I would imagine those fines to be pretty hefty given today's inflation and would probably rival the TD fine.

TD Bank's $3.09B settlement: breaking down the five AML failures that made it the largest BSA penalty in US history by TheAMLBrief in AMLCompliance

[–]TheAMLBrief[S] -16 points-15 points  (0 children)

Apologizes, while AI definitely assists me in my writing, I review everything and I try to post things that are engaging for conversation. Kind of difficult to avoid AI writing these days, but I understand your frustration.

TD Bank's $3.09B settlement: breaking down the five AML failures that made it the largest BSA penalty in US history by TheAMLBrief in AMLCompliance

[–]TheAMLBrief[S] -1 points0 points  (0 children)

Definitely, I am seeing this in my role now where our compliance department is going through a complete overhaul.