Taylor Twining, CAMS

Sarah Beth Felix asks the same question I have ... On July 16, 2024 FinCEN, OFAC, and the FBI issued a joint notice titled “Timeshare Fraud Associated with Mexican-based Transnational Criminal Organizations” - https://lnkd.in/ePaZK3Ga The Notice included this: “Given the transnational nature of illicit activity related to timeshare fraud in Mexico, FinCEN also encourages U.S. financial institutions to continue to use, and potentially expand, their existing processes to collect and share information with foreign financial institutions in furtherance of investigations that involve cross-border activity.” That excerpt included a citation, Footnote 40: See, e.g., FinCEN, “Prepared Remarks of FinCEN Director Andrea Gacki During the SIFMA AML Conference” (May 6, 2024) at https://lnkd.in/gYAk7EYk I am not aware of any authority – law or regulation – that allows US-based and regulated financial institutions to share information with foreign financial institutions in furtherance of investigations that involve cross-border activity. And I’ve read Director Gacki’s May 6, 2024 speech: there is nothing in it that refers to US-based and regulated financial institutions being allowed to share information with foreign financial institutions in furtherance of investigations that involve cross-border activity.

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In its recent statement, The Wolfsberg Group set out guidance for financial institutions on why monitoring for suspicious activity (MSA) should be a priority over monitoring of transactions only. Here are five takeaways: 1. MSA system effectiveness should be prioritized over direct equivalence with legacy platforms 2. Detecting crystalized financial crime risk rather than theoretical risk should be a focus 3. Sandbox development should be embraced instead of parallel processing 4. Customer and transaction risk need to be monitored, rather than just transactions 5. Banks need technology that supports an MSA approach, providing access to real-time, contextual insights using machine learning, cluster analysis, entity resolution, and graph network analysis Read the full article: https://lnkd.in/eaR-Qxx5 If you'd like to know more about how Hawk can help you to implement an MSA approach to anti-financial crime, request a demo: https://hawk.ai/ #aml #fincrime #wolfsberggroup #compliance #banking #payments #frauddetection #ai #artificialintelligence #suspiciousactivity

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Katherine Ford, Associate Director, Strategic Operations at Financial Crimes Enforcement Network will give a keynote at RegTech Summit New York on November 21st, to discuss managing regulatory expectations and best practices for fighting financial crime, including: ✅Overview of FinCEN’s role in the regulatory landscape, including recent updates to anti-money laundering (AML) and combating the financing of terrorism (CFT) regulations. ✅Discussion of the consequences of non-compliance and recent enforcement actions. ✅How financial criminals are adapting to new technologies and market conditions, and the implications for financial institutions. ✅Recommendations for implementing effective AML/CFT programs, including the use of advanced data analytics, machine learning, and other technologies to detect and prevent financial crime. Don't miss this one - register here: https://lnkd.in/eqq-PbxD #RTSNYC #regtech #regtechsummit #FinCEN #financialcrime #AML #CFT #compliance #dataanalytics #machinelearning

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Katherine Ford, Associate Director, Strategic Operations at Financial Crimes Enforcement Network will give a keynote at RegTech Summit New York on November 21st, to discuss managing regulatory expectations and best practices for fighting financial crime, including: ✅Overview of FinCEN’s role in the regulatory landscape, including recent updates to anti-money laundering (AML) and combating the financing of terrorism (CFT) regulations. ✅Discussion of the consequences of non-compliance and recent enforcement actions. ✅How financial criminals are adapting to new technologies and market conditions, and the implications for financial institutions. ✅Recommendations for implementing effective AML/CFT programs, including the use of advanced data analytics, machine learning, and other technologies to detect and prevent financial crime. Don't miss this one - register here: https://lnkd.in/exKVmZng #RTSNYC #regtech #regtechsummit #FinCEN #financialcrime #AML #CFT #compliance #dataanalytics #machinelearning

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Katherine Ford, Associate Director, Strategic Operations at Financial Crimes Enforcement Network will give a keynote at RegTech Summit New York on November 21st, to discuss managing regulatory expectations and best practices for fighting financial crime, including: ✅Overview of FinCEN’s role in the regulatory landscape, including recent updates to anti-money laundering (AML) and combating the financing of terrorism (CFT) regulations. ✅Discussion of the consequences of non-compliance and recent enforcement actions. ✅How financial criminals are adapting to new technologies and market conditions, and the implications for financial institutions. ✅Recommendations for implementing effective AML/CFT programs, including the use of advanced data analytics, machine learning, and other technologies to detect and prevent financial crime. Don't miss this one - register here: https://lnkd.in/g-TAXGJ8 #RTSNYC #regtech #regtechsummit #FinCEN #financialcrime #AML #CFT #compliance #dataanalytics #machinelearning

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📣 New Member Alert 📣 The Financial Crimes Enforcement Network (FinCEN, part of the Treasury Department)'s Beneficial Ownership Information (BOI) Reporting Rule is now in effect. The deadline to file is January 1, 2025. Members of JVC can check their email inbox or log in to the Dashboard (https://lnkd.in/eUTDU8qr) to read JVC's guidance on this important filing requirement for most businesses registered to do business in the US, including domestic and foreign LLCs and corporations. Have questions? Contact JVC today! [email protected] #jewelryindustry #legal

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Hey fraud investigators! If you're headed to the ACFE's 35th Annual Fraud Conference this week, stop by booth 101 to say hello and learn how Case IQ can improve your investigations. #fraudconf #acfe #fraud #fraudinvestigator

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📢 New Guidelines Alert! In 2017, the Office of the Superintendent of Financial Institutions (OSFI) issued Guideline E-23, outlining model risk management (MRM) requirements for federally regulated deposit-taking institutions. Fast forward to November 2023, OSFI has released a revised Draft Guideline E-23, effective July 1, 2025. Read more here: https://ow.ly/7StL50SqTIN (subscribe for free to read the full article) #CFASocietyToronto #CFAToronto #OSFIGuideline #Compliance #FinancialRegulations

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Last month, the Financial Crimes Enforcement Network (FinCEN) added 16 new questions to the Beneficial Ownership Information (BOI) FAQs. Here’s what’s new, by category, sourced from fincen.gov. 👇 #beneficialownership #beneficialownershipinformation #fincen

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For GIR Americas Investigations Review 2025, FRA experts unpack regulatory trends and investigative techniques relating to cryptocurrency fraud and compliance https://lnkd.in/esawte4V and ESG issues https://lnkd.in/eyivh_iy. As cryptocurrencies and ESG continue to be top of mind for investors and regulators alike, bad actors will continue to look for opportunities and incentives to defraud and deceive stakeholders. Multiple regulators in the Americas identify these areas as priorities and practitioners should remain aware of the trends and regulatory developments. Many of the necessary investigative techniques will be familiar to experienced practitioners, although often requiring a slight nuance or different technologies. Jenna Voss, Masako Asaka, CPA, CFE, Danielle L., Umair Nadeem, Meredith Fitzpatrick Global Investigations Review #ESG #Cryptocurrency #Fraud #Investigations #Technology

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🗽Looking forward to seeing the NYC financial crime investigations community! FinAware is proud to be the premiere sponsor for the International Association of Financial Crimes Investigators IAFCI NY Metro Chapter One Day Fraud Training Event. October 10, 2024. 𝑹𝒆𝒈𝒊𝒔𝒕𝒓𝒂𝒕𝒊𝒐𝒏 𝒊𝒔 𝒏𝒐𝒘 𝒐𝒑𝒆𝒏. Link in comment section. The FinAware team will be on hand demonstrating the newest and most powerful financial investigations support tool available for financial investigators and forensic auditors. Using the latest #ai technology, FinAware organizes your financial data, such as bank statements, by reading, extracting and analyzing your financial data. Drag and drop your financial records and with one click of the mouse, create Excel spreadsheets, graphs, timelines, and charts. Query your data in natural language. Eliminate hours and hours of data management and organization. Seize and recover funds quicker. Create courtroom ready visuals. No code No templates Just drag, drop, & analyze. Want to learn more about FinAware? Watch this three-minute video. https://lnkd.in/ecwaRh-U Are you ready to put the power of non-predictive AI to work in your financial crime investigations? P.S. Are you a 𝐜𝐫𝐲𝐩𝐭𝐨 𝐢𝐧𝐯𝐞𝐬𝐭𝐢𝐠𝐚𝐭𝐨𝐫 overwhelmed by organizing massive amounts of crypto exchange returns? Drop "crypto" in the comments and be the first to try out CryptoAware.

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**ACTION REQUIRED!** The U.S. Government Financial Crimes Enforcement Network (FinCEN) has a new beneficial ownership information reporting requirement.   If you do business in the U.S. through an entity, then you have until January 1, 2025 (or, if your company was formed after January 1, 2024, then you have just 90 days after formation) to file a beneficial ownership report (BOI) with FinCEN. It is simply a form that tells them who owns or controls the business—and therefore who receives the income from the business. It’s designed to catch money-laundering and other financial crimes.   Who is required to file? All for-profit entities (e.g., an LLC, S-corporation, LLP, etc.) must file a BOI with FinCEN. If you are a 501(c)(3) non-profit, or if you do business as a sole proprietor, you are not required to file a BOI.   You can file the report for free directly through the FINCEN government portal, which you can find (along with information about the filing requirement) here: https://fincen.gov/boi. It only takes a few minutes. You will need the SSN and a copy of a government ID (e.g., a passport or a driver’s license) for all beneficial owners.   Who is a beneficial owner? A beneficial owner is any individual who, directly or indirectly either: (1) exercises substantial control over the company (the CEO, for example); or (2) owns or controls at least 25% of the company.   There are no annual reporting requirements after your initial BOI filing—but you do need to report any changes (e.g., if you change your office or residential address, or if your company changes hands) within 30 days after the change.   Please don’t hesitate to reach out if you have questions, or if there’s anything we can do to assist!

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In our last posting, part 1 of a 4-part series, we mentioned that FinCEN’s Proposed Rule to Strengthen and Modernize Financial Institution AML/CFT Programs from (June 2024) will likely result in BSA Officers having to proactively evidence the effectiveness of the design of their AML/CFT program, and evidence then the effectiveness of the controls in place to address the AML #Priorities and the remaining elements of the Proposed Rule from June 2024. A road map for this is discussed below, and will continue in part 3 and 4 of this series of postings. Policies/Procedures: Update policies/procedures with descriptive language to address the new #compliance requirements in order to evidence the design of the Program. Those policies and procedures will need to incorporate the National Priorities, should call for mandatory risk assessment that also incorporates the National Priorities, call for Training that addresses program updates, and call for more robust reporting to executives and the Board as they exercise their oversight of the Program. #AML systems and the associated Model Validation may be affected as well, and will require procedure updates. BSA/AML/CFT Risk Assessment: Under the Proposed Rule, the risk assessment will become a required element of a program. The risk assessment should address the most current AML National Priorities at the time, and any other illicit finance activity risks based on the financial institution’s business activities. The results should directly drive the training program, the nature and scope of monitoring, and AML Model rules and parameters. A best practice is to present this risk assessment to an internal risk committee and either the Board of Directors or one of its risk committees. While it’s great that the #FinCrimes department understands the institution’s BSA/AML/CFT risks, it’s even more important that the rest of the institution understands them. In part 3 of this series of postings, we’ll discuss Training, AML Monitoring Systems, and Board Oversight. #riskassessment #nationalpriorities #AMLtraining #modelvalidation

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🚨 FinCEN Hosting Webinar Today: How to Comply with Beneficial Ownership Reporting Requirements 🚨 U.S. Department of the Treasury's #FinCEN is offering a not-to-be-missed webinar in just four hours (at 2PM EST) on how businesses can adhere to the new #BeneficialOwnership reporting requirements under the #CorporateTransparencyAct. 🔍 What You Will Learn: ✔️ The essentials of #BeneficialOwnershipReporting. ✔️ Detailed steps on how to comply with the law. ✔️ Insights directly from #FinCEN representatives. Whether you're a startup founder, a compliance officer, or simply involved in a business operating in the U.S., this session will provide you with the necessary tools to ensure your company meets all new legal requirements. 🔗 Don't miss out on this opportunity to gain valuable insights and stay ahead of compliance issues. Join us at #FinCEN’s YouTube Channel! 👉 Watch Live Here: https://lnkd.in/duxHHWT3 #AML #BSA #ACAMS #CAMS #FinancialCrimes #FinancialCrimesPrevention #CTA #BeneficialOwnershipRule #FinCEN #BeneficialOwnership

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Katherine Ford, Associate Director, Strategic Operations at Financial Crimes Enforcement Network (Financial Crimes Enforcement Network, US Treasury) will give a keynote at RegTech Summit New York on November 21st, to discuss managing regulatory expectations and best practices for fighting financial crime, including: ✅Overview of FinCEN’s role in the regulatory landscape, including recent updates to anti-money laundering (AML) and combating the financing of terrorism (CFT) regulations. ✅Discussion of the consequences of non-compliance and recent enforcement actions. ✅How financial criminals are adapting to new technologies and market conditions, and the implications for financial institutions. ✅Recommendations for implementing effective AML/CFT programs, including the use of advanced data analytics, machine learning, and other technologies to detect and prevent financial crime. Don't miss this one - register here: https://lnkd.in/eGS_YVeC #RTSNYC #regtech #regtechsummit #FinCEN #financialcrime #AML #CFT #compliance #dataanalytics #machinelearning

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Katherine Ford, Associate Director, Strategic Operations at Financial Crimes Enforcement Network (Financial Crimes Enforcement Network, US Treasury) will give a keynote at RegTech Summit New York on November 21st, to discuss managing regulatory expectations and best practices for fighting financial crime, including: ✅Overview of FinCEN’s role in the regulatory landscape, including recent updates to anti-money laundering (AML) and combating the financing of terrorism (CFT) regulations. ✅Discussion of the consequences of non-compliance and recent enforcement actions. ✅How financial criminals are adapting to new technologies and market conditions, and the implications for financial institutions. ✅Recommendations for implementing effective AML/CFT programs, including the use of advanced data analytics, machine learning, and other technologies to detect and prevent financial crime. Don't miss this one - register here: https://lnkd.in/eGS_YVeC #RTSNYC #regtech #regtechsummit #FinCEN #financialcrime #AML #CFT #compliance #dataanalytics #machinelearning

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Two U.S. financial regulators move to strengthen AML measures by introducing new rules for fund advisers, signaling a commitment to combating financial crimes in the investment industry. https://buff.ly/3QUMNsv #Regulation #MoneyLaundering #ComplianceEfforts

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