AFC Policy Archives - Page 4 of 4

AFC Policy, Europe, March – May 2016

How Terrorist Trends Evolve and How Financial Institutions Should Respond

March 7, 2016May 9, 2016 /2 Comments

As we move into and through 2016, the most significant terrorist threats to Western society are posed by Islamic terrorist or jihadist organizations. As evidenced by the attacks in Paris on November 13, 2015, the subsequent disruption of imminent attacks in Europe in November and...

AFC Policy, March – May 2015

Virtual Currencies Continue to Peek through the Shadows

March 3, 2015March 4, 2015 /Leave a comment

Virtual currencies burst into the public eye in the summer and fall of 2013 with headline-making enforcement actions around money laundering, narcotics trafficking and unlicensed money transmission. Initial concerns focused on the illicit threat of anonymous users permeating the dark Web to conduct nefarious...

AFC Policy, June - August 2014

Wolfsberg Group Updates Correspondent Banking Guidelines

June 4, 2014March 6, 2015

On February 18, 2014, the Wolfsberg Group of International Financial Institutions, an industry consortium that sets international industry anti-money laundering (AML) standards, issued updates to its AML Principles for Correspondent Banking.1 The updates are in response to the increasing regulatory focus on the AML...

AFC Policy, March - May 2014

Goldilocks and the Three Sanctions

March 4, 2014September 4, 2015 /Leave a comment

In the fairytale, the little girl named Goldilocks had a choice of three beds in which to take a nap. The father's bed was too hard, the mother's was too soft, and only the baby bear's bed was comfortable enough for her in which...

AFC Policy, December 2012 – February 2013

Section 314(b) Information Sharing Revisited

December 4, 2012March 5, 2015 /Leave a comment

The USA PATRIOT Act was signed into law by President George W. Bush on October 26, 2001. It was enacted as a result of the terrorist attack of September 11, 2001 (9/11). With the thought of 9/11 in mind, the PATRIOT Act was intended to...

AFC Policy, June 2011 – August 2011

The Death of Osama bin Laden and Our Fight Against Terrorist Financing

August 29, 2011May 28, 2015 /Leave a comment

On May 1, 2011, President Barack Obama informed America and the world that Osama bin Laden, leader of the terrorist al Qaeda network, had been killed in Abbottabad, Pakistan. The stunning announcement marked the most important accomplishment in the United States' efforts to combat global...

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AFC Policy