- 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
- Banks are closing accounts with partner MSBs due to the high-risk nature of the transactions.
Driven by increased bank regulatory scrutiny, many banks are electing to close MSB accounts to minimize risks of money laundering, fraud and financial crime. It is crucial that MSBs have solid AML Compliance Programs and controls in place and provide that information to their banking partner to assure them that the risk of banking them is mitigated by those controls.
- The economic environment remains challenging and thus has put resource pressure on AML Compliance Programs.
Some MSBs are reacting to economic pressures by cutting AML programs. It is imperative that adequate staffing and resources remain dedicated to transaction monitoring, employee training and agent oversight. Failure to do so will result in regulatory actions and the potential of criminal indictment.
- Regulatory requirements continue to shift and change, requiring MSB AML Compliance Programs to remain nimble and attentive to independent review.
The Independent Review Report is the MSB's assessment of the adequacy of its’ AML program. An MSB should pay careful attention to the findings of the independent review and adopt all recommendations. This will ensure that the company is prepared to regulatory examinations.
- MSB's agents have unwittingly and, in some cases wittingly, been involved in dealing with criminal fraud rings.
Compliance officers must insure that all employees are trained in recent fraud schemes so that they can identify and report suspicious activity. MSB's must also have robust branch and agent oversight programs to insure that all employees are complying with company AML policies and procedures.
- Companies are paying severe financial penalties for not demonstrating thorough use of reasonable measures to prevent being used by criminal organizations or sanctioned regimes.
MSBs should review recent penalty actions issued by regulators to identify deficiencies that the authorities cited in AML programs. Many times similar deficiencies exist within your own MSB.
- State and federal regulators are increasing scrutiny over MSB activity.
In the past several years, major licensed money transmitters have been issued multi-million dollar penalties because of their agents' involvement with money launderers and fraud rings. It is imperative that MSBs have controls over their agents' activity through a robust Agent Oversight Program