by georgeoself | Bank Compliance, BSA Anti-Money Laundering, BSA Compliance, Compliance
Back in the day, most of us in small financial institutions were taught some variation of the “Appendix J” risk assessment. That was OK until recently. Now, it’s not really good enough and we think FIs are going to have to do better. We think there are major...
by georgeoself | Bank Compliance, Bank Secrecy New Rules Beneficial Ownership, BSA Anti-Money Laundering, BSA Civil Money Penalty, BSA Compliance, Compliance, Report on Beneficial Ownership
I just finished soul-crushing assignment: develop a BSA training slide deck for the Board. My instructions: “You only have 10 minutes. Keep it high level. It’s all the Board can stand.” I got it done, but I don’t feel good about it. I think all I did was...
by georgeoself | Bank Secrecy New Rules Beneficial Ownership, BSA Anti-Money Laundering, BSA Antimoney Laundering, BSA Civil Money Penalty, BSA Compliance, Compliance, Report on Beneficial Ownership, Unfair and Deceptive Bank Practice
New Beneficial Ownership Rules Coming for All Commercial Accounts The US Treasury is about to require that banks gather information about beneficial ownership for all corporate accounts. The rule, which will be subject to comment before becoming a final , is likely...
