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Tagged ‘AML’


Laura Goldzung

Getting to Know Anti-Money Laundering Expert            Laura Goldzung

In this "Getting to Know" post, we spoke with TrustedPeer Expert Laura Goldzung. Laura is the founder and president of AML Audit Services, and she has more than 30 years of financial industry experience including AML compliance and training, and securities firm operations and management.

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  1. Why did you decide to join TrustedPeer?
    The opportunity to join TrustedPeer presented itself through a colleague who is an adviser to the board. I thought it was a very unique opportunity because, as a service provider and consultant in AML, it’s hard to find the time to do develop consulting opportunities and get exposure to potential clients. TrustedPeer presented the prospect for greater exposure and added value to my practice.

  2. What are you most excited about in Anti Money Laundering right now?
    There are still many issues facing financial institutions with respect to AML that don’t seem to be going away. There is still quite a bit of challenge in maintaining required compliance. What I’m most excited about is that more and more people are getting into the field, and more of the financial institutions are getting better educated about AML compliance. It’s exciting to work with unique, emerging companies and platforms. It’s always a new day in AML.

  3. How has technology changed AML?
    Technology enables AML compliance, but it’s not the only enabler. A hybrid activity between automation, technology, and human skill is required. You can’t replace human skill with technology. You need to have the competencies to leverage what the technology tools and the advances in technology bring to the practice. For example, if you’re a large bank, you likely have many tools you use to monitor transactions and there are different facets to each transaction. There are many smaller companies that don’t use AML systems and instead use manual processes. Technology is exciting and enabling, but it requires human intervention.

  4. Can you tell us about an “aha” moment in your career?
    My first aha moment was when a new client called me again for new services. Beyond that, my “aha” moments manifest as more of a sustained stream of learning for me and for my client base. I do a lot of teaching, and there are plenty of moments when something just clicks for those audiences.

  5. Where do you predict the future of AML going?
    It’s just going to get bigger and bigger. There’s opportunity for an organic expansion in that there are new industry sectors that will be subject to AML compliance. Some already perform it as a best practice, and there are a couple of new sectors that will be facing a requirement to implement a program. There are also new and emerging products like Bitcoin and emerging issues such as marijuana dispensaries that come with a lot of controversy. There are many payment processor companies who now include AML compliance as a best practice because their bank and other partners may feel more comfortable if they have a program in place. All in all, AML is evolving rapidly.

To read more about Laura’s area of expertise or to book an Expert Session, visit her Meet The Expert page on our site.

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Dennis Lormel

Uncovering Fraud:  A Whistleblower's True Story of Courage in Compliance

This is the true and compelling real life story of a Bank Secrecy Act (BSA) and Bank Compliance Officer. Cathy Scharf had been recently hired by a small community bank. Shortly into her tenure at the bank, she realized something was seriously wrong. The compliance officer determined that the bank was processing an inordinate and unreasonable amount of transactions per month; well in excess of what a bank that size should have been handling. She learned that the bank was dealing with third party processors and subsequently found out that the third party processors were transacting on behalf of internet poker companies. The compliance officer knew this activity was illegal. She went to the bank president and other executives to attempt to exit the business relationships and file suspicious activity reports (SARs). Although the compliance officer continuously attempted to do the right thing, she was constantly rebuffed or misled.

What became apparent was that the tone at the top was not compliance friendly. Regardless of how dedicated and committed to doing the right thing a compliance professional is, if executive management does not adhere to a culture of compliance and exhibit the proper tone at the top, the compliance function is destined to fail. For approximately one year, the cultural conflict played out until state regulators closed the bank.

During that year, as the gripping story unfolded, the compliance officer experienced many emotions ranging from stress and sleeplessness, to intimidation, guilt and fear for her safety. In addition, she incurred legal expenses to retain a lawyer. Despite her distress, she continued to try to do the right thing. As things progressed, the compliance officer cooperated with law enforcement and regulatory authorities.

The Players

This saga contained various backstories involving a number of colorful characters. The law enforcement investigation began as an organized crime investigation into gambling. Organized crime led investigators to information regarding offshore payment processing in Costa Rica. Investigation led to third party processing; processing for a range of illicit activities to include gambling on internet poker. Most banks would not wittingly service internet poker companies. Third party processors relied on shell and shelf companies, nominees, and other mechanisms, to create the appearance that funds were being moved for licit and innocuous activities and not for illicit purposes.

There were organized crime figures in New York associated with the Gambino and Genovese families. There was Anurag Dikshit, a citizen of India, who owned PartyGaming, an internet gaming business. Dikshit pled guilty to internet gambling in December 2008, and agreed to forfeit $300 million. There was Daniel Tzvetkoff, an Australian, who made an estimated $82 million processing for PokerStars, Full Tilt Poker and Absolute Poker. In 2010, Tzvetkoff was accused by the poker companies of stealing about $100 million from them. He was subsequently arrested and agreed to cooperate with law enforcement regarding other payment processors, to include Chad Elie, a key player in the SunFirst Bank case. There were PokerStars, Full Tilt Poker, and Absolute Poker, along with their owners, who were taken down on what was known as poker’s Black Friday, April 15, 2011.

The focus of this case study is on third party processors working with an insider at SunFirst Bank to process transactions for PokerStars and Full Tilt Poker. Developments in the multi-faceted investigation led the FBI to SunFirst Bank. SunFirst Bank was a small community bank located in St. George, Utah.

The most important player in this aspect of the case is Cathy Scharf. Cathy was the BSA and Bank Compliance Officer at SunFirst Bank. Her commitment to her compliance responsibilities is a demonstration of “courage in compliance.”  

Continue Reading Cathy's story here:

If you need consulting on AML, contact TrustedPeer Expert Dennis Lormel.

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Dennis Lormel

Thinking Like a Bad Guy in Order to Do Good

When it comes to fraud and money laundering, can you think like a bad guy? The truth is, we all can. However, many of us do not realize this fact. More importantly, most of us possess a high level of personal integrity that precludes us from considering the temptation of accepting the opportunity to commit fraud. Unfortunately, a good number of people do succumb to the lure of fraud. The frauds these unscrupulous individuals perpetrate can be extremely devastating.  This was never more evident than it has been More

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