How do we keep up to date with FinCEN Advisories and SAR Key Terms?
If you haven’t already, subscribe to FinCEN Notifications. FinCEN regularly releases updates, advisories, and guidance regarding SAR reporting and key terms. Subscribing to their email list or checking their website frequently helps ensure you stay informed of changes, especially regarding emerging threats like fraud schemes, money laundering, or cybercrime. The link to register can be
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Is there a specific frequency for BSA/AML/OFAC model tuning?
Answer: There is not a one-size-fits-all frequency for tuning BSA/AML/OFAC systems. The frequency depends on several factors, including regulatory expectations, significant changes in business operations, risks, and system performance. However, Supervisory Guidance on Model Risk Management and best practices suggest the following guidelines for model tuning: Remember to document any tuning efforts – this gives
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Planning for a Successful Automated Monitoring System (AMS) Validation by Understanding Common Findings
Your AMS plays a crucial role in helping financial institutions detect and prevent illicit activities. However, to ensure the effectiveness and compliance of these solutions, regular model validations are necessary and prescribed by Guidance on Model Risk Management from the prudential regulators. During validations, common findings often emerge and highlight opportunities for improvement. Here, TCA
AML/CFT Transaction Monitoring – Importance of Tuning Your AMS Model
Regulators expect compliance with the standards established in the model risk management guidance (MRMG) (Federal Reserve SR Letter 11-7, OCC Bulletin 2011-12; FDIC FIL 22-2017) as well as the April 9, 2021, Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money Laundering Compliance. This guidance relates to systems or models used
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Identifying Higher Risk Customers using Keyword Searches
Financial institutions are facing increased regulatory pressure on Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures, particularly regarding inherently higher-risk customer types. CDD is critical to identifying and monitoring customers involved in higher-risk activities. Identification of higher-risk customers starts at account opening and your account opening procedures should incorporate this due diligence. Some
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When dispositioning alerts from our automated BSA/AML monitoring system, how much information is enough?
Answer: TCA continues to see examiner scrutiny on alert resolution. When documenting a response to an alert, it does not need to be as in-depth as an investigation narrative; however, it must explain the who, what, where, when, why, and how. This creates continuity for other BSA staff, examiners, and auditors to understand how you
