“From Capone To Compliance” AML essentials training seminars for individuals and institutions working in the financial sector, business sector, and law enforcement.
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Anti-Money Laundering in a Nutshell
Awareness and Compliance for Financial Personnel and Business Managers.” Kevin Sullivan, CAMS draws on a distinguished career as an AML agent and consultant to impart an insiders knowledge and experience of AML. He’s written this practical guide to compliance to teach financial professionals, corporate investigators, business managers, and law enforcement what money laundering is, who does it, how they do …
SAR Gazing In A Post 9/11 World
On this, the 18th anniversary of the 9/11 attacks, I reminisce my experience and consider where the financial community is today. As an Investigator with the New York State Police detailed to NY HIFCA El Dorado Task Force, our offices were located at 26 Federal Plaza, just a few blocks away from the World Trade Center. For several months, every single …
Varsity Blues And A Cocaine Cruise – Media Headlines And Your Role
In the last few days there have been two major predicate crime incidents. One is the university admissions scandal and the other is a drug bust in NYC. I would like to address the role a financial institution should be playing in ongoing law enforcement investigations. Several institutions have already been contacted and subpoenas have been issued. However, financial institutions …
3 Signs of an Effective AML Course
More and more businesses are catching on the importance of anti-money laundering (AML) training. However, as you hear or read the latest regulatory actions against various financial institutions, you will almost always see lack of training listed in the deficiencies section of the action. With proper AML training, both individuals and large institutions who satisfy their regulatory obligations and more importantly who …
Inside The White Collar Criminal Mind (Predictive forecasting or palm reading?)
While doing my research for this article I ended up going to a psychic. I wanted to see how accurately a psychic could predict my personality. It seemed the accuracy of the predictions had an unusual correlation to the amount of cash I paid. I should have known better, while doing the card reading the psychic kept asking me, “hit or stand …
A SAR IS BORN
Suspicious Activity Reporting (SAR) is an AML procedural topic that confuses many and harvests many varied positions and opinions. Most people having anything to do with a SAR or potential SAR have never seen one written by another financial institution and perhaps have never even seen their own since that duty may be delegated to a special SAR writing team within …
Developing the Investigative Mind
A bad guy thinks like a bad guy. He does bad guy things. He acts like a bad guy. He spends his day trying to think up more bad guy things to do. He associates with other bad guys who all do more bad guy things. He goes to the annual bad guy convention and trade show. He reads “Bad …
Voo-Due Diligence
So you think all is well with your compliance/AML system…Your deflector shields are up and on maximum. OFAC – check; Patriot Act – check; BSA – check; Green lights across the board…check – check – check. You are sure all is well, perhaps you can now even relax, put your feet up, take off early, hit the shore, have a …
Dancing with the SARs: Navigating the BSA Suspicious Activity Report
Way back in the Mesopotamia Era… well, ok, it was really only 1992, but it just feels like such a long time ago as so much has changed in the past 26 years. The Annunzio-Wylie Anti-Money Laundering Act of 1992 regulated financial institutions to report suspicious transactions by completing a Suspicious Activity Report (SAR). The US PATRIOT Act of 2001 …