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SARs That Count: Words Matter
When the Financial Crimes Enforcement Network issued its Advance Notice of Proposed Rulemaking in September 2020, titled “Anti-Money Laundering Program Effectiveness,” it marked a significant shift in how anti-money laundering (AML) programs will be evaluated, with emphasis on implementing “effective and reasonably designed” AML programs.
ACAMS Stars Lead the Way in 2024
The achievements of five anti-financial crime (AFC) professionals as well as one ACAMS chapter were recognized during an awards presentation that took place at The Assembly Las Vegas in September at the Aria Resort and Casino.
From the Editor
My Mother Has a Saying…
In reading the articles on offer in this edition, I began thinking about effective communication and what it really entails. An example from my childhood came to mind. One of the most effective communicators I know is my mother. For as long as I can remember, she has used idioms (also known as “dichos” in Spanish).
Inside this Edition
- Acceso LatAm
- AFC Challenges
- Awards
- Badge Bulletin
- Career Guidance
- Compliance
- Europe Express
- Financial Crime Matters and Beyond
- Fraud
- Know Your Chapter
- Meet the ACAMS Staff
- Member Spotlights
- Practical Solutions
- Regulatory Initiatives
- Sanctions
Ethical Compliance in Latin America―Advances and Challenges
AML/CTF and ethical compliance in Latin America have made progress in recent years, although they still face significant challenges. Many countries have implemented more robust legal frameworks and strengthened their institutions to combat money laundering.
The Status of Cannabis Banking in 2024
Cannabis-related banking and regulation evolved rapidly in 2024, as legalization at the federal level attracted endorsements from all sides of the political spectrum, banking reform inched toward consensus in Congress, and state-level regulatory regimes expanded their reach to encompass the 80% of U.S. residents that now live in a state with a regulated cannabis market.
ACAMS Stars Lead the Way in 2024
The achievements of five anti-financial crime (AFC) professionals as well as one ACAMS chapter were recognized during an awards presentation that took place at The Assembly Las Vegas in September at the Aria Resort and Casino.
IRS-CI: Following the Financial Crime Trail
You may be asking yourself, “Why is someone from the Internal Revenue Service Criminal Investigation (IRS-CI) division writing about the cyber world?” Well, let us put it this way: As money moves around the world, IRS-CI is following the money used by criminals to build criminal financial investigations.
AI Is Giving Job Seekers ‘Ghost Confidence’
Let us take a moment to recall this curious headline from March 2023: “Homeless Man Lands Job After Using ChatGPT for Resume and Interview Prep―A 45-year-old homeless man in Chicago used public library computers to access ChatGPT, which helped him craft a compelling resume and prepare for job interviews."
SARs That Count: Words Matter
When the Financial Crimes Enforcement Network issued its Advance Notice of Proposed Rulemaking in September 2020, titled “Anti-Money Laundering Program Effectiveness,” it marked a significant shift in how anti-money laundering (AML) programs will be evaluated, with emphasis on implementing “effective and reasonably designed” AML programs.
AML/CTF Rules Guide―Effective Public Commenting
On July 3, 2024, FinCEN published a proposed anti-money laundering/counter-terrorist financing (AML/CTF) “program” rule in the Federal Register. The publication gave the public notice of the proposed rule, invited the public to submit comments within 60 days, and provided a cost and burden estimate.
SAR Optimization: Seeing the Forest Beyond the Trees
Suspicious activity reports (SARs) provide crucial intelligence that helps law enforcement develop cases, uncover assets and discover connections to investigate criminal networks. However, the sheer volume and complexity of SARs make them difficult to analyze efficiently.
EMPACT: Europe’s Flagship Instrument Against Crime
At first glance, there appeared to be nothing unusual when―between 2022 and 2023―a group of scholars requested access to rare Russian literary works from historical and national libraries across Europe. But when the returned editions by Alexander Pushkin, Nikolai Gogol and others were found to be flawless replicas months later, it became clear that a highly organized and sophisticated heist had taken place.
Financial Crime Matters and Beyond: Head and Heart
Whether it is investigators following the proceeds of human trafficking or compliance officers filing suspicious activity or currency transaction reports on funds tied to child exploitation, dispassionately collecting evidence is crucial to catching and convicting the bad guys.
Practical Solutions for Preventing Boiler Room Fraud
The battle against boiler room fraud is being led by technological advancements, with artificial intelligence identifying the faintest ripples that might indicate suspicious behavior and tools like graph technology, real-time surveillance and anomaly detection leading the charge. In this rapidly evolving landscape, financial institutions are constantly adapting their defenses to stay ahead of increasingly sophisticated fraudsters.
ACAMS Greater Phoenix Chapter: Public-Private Insights on Financial Crime
In October, the ACAMS Greater Phoenix Chapter hosted its 2024 Forum, featuring speakers from both the public and the private sectors. The event drew more than 100 attendees from more than a dozen financial institutions. This forum provided an excellent opportunity for professionals to engage with experts from both the public and private sectors, culminating in a post-event happy hour that facilitated networking and further discussions with speakers and peers.
Taro Fukumoto: Expanding ACAMS’ Presence in Japan
Taro Fukumoto is ACAMS’ country senior manager for business development in Japan. After starting his career as an advertisement designer, Tokyo-based Fukumoto moved to marketing before spending the last more than 17 years in sales. He joined ACAMS in 2019 as a senior business development manager and advanced to his current position in 2020.
Thomas M. Fattorusso Jr.—New York, USA
Thomas M. Fattorusso Jr. recently retired as the special agent in charge of the Internal Revenue Service Criminal Investigation’s (IRS-CI) New York Field Office, covering New York State―from the five boroughs and Long Island up to the New York-Canadian border.
Melissa Mantooth, CAMS—Alabama, USA
Melissa Mantooth grew up aspiring to be a police officer, inspired by her grandfather, who served as a local officer in Birmingham, Alabama. Like many kids, her ambitions shifted over time, from teacher and band director to Federal Bureau of Investigation agent and music business executive, always drawn to roles involving math, which she loved.
Kitty Wut, CAMS—Hawaii, USA
Kitty Wut was born and raised in Hong Kong and attended the University of Hawaii at Manoa in Honolulu, where she graduated with the degree of Bachelor of Business Administration in Accounting and started working in a small, local certified public accountant firm.
Strategic Alliances: Public-Private Partnerships Against Financial Crime
In an era of rapid technological advancements, our daily interactions and work routines have evolved to transcend traditional boundaries, enabling productivity from virtually any location. This digital connectivity simultaneously presents new vectors for criminal enterprises.
Real Estate and Investment: Adapting to FinCEN’s New Rules
The end goal of most criminals is to accumulate wealth to enjoy a lavish lifestyle. However, the strong anti-money laundering (AML) framework in the U.S. makes it challenging and complicated to hide illicit proceeds or prove the legitimate source of the funds in question.
Balancing Costs and Strict Liability: A New Normal
The ongoing convergence of the world’s financial and physical supply chains has created new regulatory realities. For financial institutions and the supply chains they finance, operationalizing while optimizing sanctions and trade control compliance processes and procedures can be challenging.