Posts Tagged ‘AML Policy Manual

January 1st, 2015

178 Billion in Fines

178 Billion in Fines 2014 has set a record for fines. According to an article in the Bank Rate 2014 has been the most expensive year on records for fines […]

April 1st, 2014

AML and OFAC Applies to State Governments

AML and OFAC Applies to State Governments I had a short conversation, off the record, with several investigators that work for state unemployment agencies. The common complaint was the inertia […]

March 1st, 2014

Simple Lesson on Bribery

Simple Lesson on Bribery So, we campaign loudly against bribery.  Yet some say – ah yes, but when does a gift between friends become a bride?  The answer is when […]

November 1st, 2013


PEPs PEPs, or Publically Exposed Persons, require enhanced due diligence, NOT because they are more likely to be money launders as many overwrought risk managers and silly compliance people seem […]

November 1st, 2013

Policy Manuals

Policy Manuals Here are a couple of thoughts regarding policy manuals in general All policy manuals are  really just  documents copied from somewhere else.  The copies bring with them all […]

May 31st, 2013

AML and The Securities Industry

AML and The Securities Industry The securities industry is in for a very rude and expensive awaking.  The securities markets, commodities markets, and hedge funds are being used to launder […]

February 1st, 2013

A Question Of Due Diligence

A Question Of Due Diligence The crime of money laundering continues to be a growing area of concern in the United States. Law enforcement agencies and the financial sector devote […]

October 1st, 2012

Practice at Laundering Money

This was fun – oh my gosh this was fun! Every so often we challenge each other in the office to see how good our skills can be in the […]

September 1st, 2012

The Confusion of CTR Exemptions

Many institutions that handle large sums of money cause a good deal of problems for those who are required to file CTR – Currency Transaction Report.  The idea is that […]

July 1st, 2012

Negotiation and Access to Information

The general consensus is that people do not like conflict and thus conflict resolution is “hard” because of this distaste.   The “This is my financial answer on offers” is the […]