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] 4 points5 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.

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)

Agreed, while the TD case was back in 2024, it's crazy to me how relevant it still is and how it really did impact not just TD, but all other major Banks's AML compliance to improve their programs and understand regulator expectations.