- 35 years of government and private sector experience in law enforcement, regulatory and management expertise in the areas of regulatory compliance, financial crimes and customs violations
- Expertise includes independent reviews and investigations, threat/risk assessments, domestic and international training, expert testimony and anti-money laundering program development
- Former Deputy Director, Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury
- Former Executive Director of Operations, Director of Financial Investigations, Group Supervisor, and Special Agent for the U.S. Customs Services
- All 10 Best Practices
- Pre-Call Discovery Process
- One-on-One Call with Expert
- Session Summary Report
- Post-Session Engagement
- Money laundering is drawing increasing attention from regulators.
The financial crisis that began in 2008 caused regulators and examiners to concentrate their attention and resources on issues threatening the very survival of some banks – residential and commercial portfolios and adequate capitalization, for example. But now they have turned their attention back to money laundering and the Bank Secrecy Act.
- The cost of AML compliance programs continues to rise.
The research firm Celent estimates that spending on anti-money laundering compliance, including operations and technology, will reach $5.8 billion in 2013. This reflects both the increase in regulatory demands and the development of organizational and technology-based best practices by financial institutions. Celent estimates $1.4 billion in technology spending alone in 2013, including $557 million on AML software. (Source: http://image.exct.net/lib/ff021672706400/d/1/amltrends2011.pdf)
- Financial institutions are seeking efficiencies in operation and technology.
Celent's survey of financial institutions found that they are responding to the increasing pressures they face in compliance and costs by trying to achieve greater efficiencies through centralization and standardization of AML operations, as well as integration of AML and anti-fraud programs.
- Money launderers are identifying new schemes in response to financial institutions' increased vigilance.
These schemes include:
- Trade-based money laundering: This is an alternative remittance system that allows illegal organizations the opportunity to earn, move and store proceeds disguised as legitimate trade. Value can be moved through this process by false-invoicing, over-invoicing and under-invoicing commodities that are imported or exported around the world. Global trade is frequently used by criminal organizations to move value around the world through the complex and sometimes confusing documentation that is frequently associated with legitimate trade transactions. (Source: http://www.ice.gov/cornerstone/money-laundering.htm)
- Using virtual currency: In contrast to real currency, "virtual" currency is a medium of exchange that operates like a currency in some environments, but does not have all the attributes of real currency. In particular, virtual currency does not have legal tender status in any jurisdiction. This guidance addresses "convertible" virtual currency. This type of virtual currency either has an equivalent value in real currency, or acts as a substitute for real currency. (Source: http://www.fincen.gov/statutes_regs/guidance/html/FIN-2013-G001.html)
- Targeting smaller banks in smaller cities: This is an attempt to take advantage of less sophisticated monitoring procedures at smaller banks.