Four months in and the anti-money laundering solution industry is still adjusting for the U.S. Department of Treasury Financial Crimes Enforcement Network (FinCen) Bank Secrecy Act (BSA) compliance update. As we prepare for all the changes to the financial industry and beyond, at IDMERIT we have noticed there isn’t much awareness about the new changes or what we have done to make BSA/AML compliance easier.
To start, IDMERIT has made changes to our services offerings that coincide with FinCen’s update and the future direction of cybersecurity protection. But what does that mean for you, our loyal clients, and partners? To understand what these changes will mean for you, your business, and your customers, let’s dive in and give you a glimpse of the major adjustments made in the Bank Secrecy Act.
What Does AML Compliance Protect?
Apart from keeping your business from regulatory fines, AML compliance does a lot for cybersecurity and the prevention of global financial breaches and terrorism financing. It prevents the entrance of bad actors into your system and keeps your business from being used as a front for money laundering. Being AML compliant also provides a blanket of security and transparency for Business-to-Business (B2B) operations.
At the onset, anti-money laundering solutions were first directed mainly to banks and the finance industry, today it encompasses all industries from Small Medium Enterprises (SME) to large corporations both online and off. As part of the Bank Secrecy Act, being AML compliant means protection from unwillingly supporting or participating in:-.
- Drug Trafficking Organization Activity
- Foreign and Domestic Terror Financing
- Cybersecurity Breaches, Illegal Virtual Operations, and Cryptocurrency
- Human Trafficking
- Professional Money Laundering Networks
- Fraud
- Corruption
- Proliferation Financing of Terror or Sanctioned Countries
To avoid being supporting actors to bad actors in crime, there are a few requirements that need to be met. These requirements do not have to be strenuous for you or your customers. Though regulatory bodies aim to secure primary operations, credit channels, supply chains, data protection, and security systems, you should not bypass the need for utilizing customer onboarding best practices.
Besides basic customer due diligence requirements of basic demographic data, AML compliance requires enhanced due diligence which includes:-
- Ongoing Transaction Monitoring and Screening
- The Assignment of A Compliance Officer
- Continuous Risk Assessment
- Regulatory Suspicious Activity Reporting
- Staff Compliance Training
- Independent Testing by an Outside Party
As part of being AML compliant, your company will be required to implement these requirements into your ID validation systems and operations. Regular independent audits for AML compliance should be undertaken under the supervision of the compliance officer. The new adjustments for the Bank Secrecy Act still focus heavily on these requirements but include new mandates and fines specifically directed towards closing any gaps in enhanced due diligence not routinely undertaken by organizations.
Provisions to Pay Attention to In the Bank Secrecy Act
The Currency and Foreign Transactions Reporting Act of 1970 commonly known as the Bank Secrecy Act (BSA) primary goal is to prevent banks and other financial institutions from being used as tools for money laundering. It has since been amended under the USA Patriot Act of 2001 to include provisions for terrorism financing.
Under the new provisions in the BSA, special focus was placed on certain industries and businesses.
- Casinos
- Depository Institutions
- Insurance Industry
- Money Services Businesses
- Mortgage Co/Broker
- Precious Metals/Jewelry Industry
- Securities and Futures
Most of these regulatory adjustments were done with these organizations in mind. These firms were chosen due to the fact they were the ones with the most issues with AML compliance and effective execution of money laundering solutions. The changes were made to address loopholes in their AML screening solutions while maintaining customer onboarding best practices.
Some of the new regulations include: –
- Personnel Rotation
- Focus on Asset Management
- Review of the Corporate Transparency Act (CTA) as it relates to Beneficiary Assessment and Screening
- Increased Global Reporting and Co-operation
- Amendments for Whistleblower Protection and Incentives
- Increased Use of AI Technology
- Increased Transparency in Operations
- Inclusion of Considerations for Wildlife Trafficking
- The Creation of FinCen Analytics Datahub
The legislative powers have come to realize that money laundering does not always mean fiat money. After tackling the cryptocurrency industry, wildlife, precious jewels, and antiquities were other areas to be addressed. Including the focus on asset management, meant all potential liquidated assets of a business and individual would be considered when creating AML compliance solutions. Frequent changing of assigned personnel was an added security measure that also helped with increased transparency in operations.
Amendments for whistleblower incentives and protections may not be a welcome addition and could have serious life-threatening drawbacks. Just as having a government-controlled datahub may not be welcomed by all industries. The use of Artificial Intelligence (AI) would make the onboarding process easier especially considering the inclusion of global beneficiary screening.
Keeping globalization in mind, FinCen along with the Office of Foreign Assets Control (OFAC) and Office of the Comptroller of the Currency (OCC) have realized there is power and safety in global collaborations. Partnering with other global partners such as European Banking Authority (EBA) gives the BSA the power to ensure AML compliance solutions are implemented, enforced, and reported globally. By strengthening the BSA’s global reach, creating an analytics data hub for AML compliance, and focusing on new AML screening solutions in challenged industries, the world can feel more at ease participating in the global economy.
5 Ways IDMERIT’S AML Compliance Solution Services Meet the New Mandates
Whether you are in the selected industries or business is irrelevant because under these new mandates all will be required to be BSA/AML compliant. Though there is still some fine-tuning to be done on the BSA in terms of foreign regulatory oversight, control, and foreign ownership, those will soon be addressed. In terms of global oversight, it is expected that the US will take the lead and ensure other regulatory bodies meet their goals.
In the interim, your business should still take advantage of the many global, AI-driven services IDMERIT provides for your AML compliance solutions.
Global ID Verification on Any Device
Going global is the theme behind the new BSA mandates, but for over 20 years IDMERIT already had a global reach with the international banking sector and corporate partners. We are the experts on global ID verification on any device with the highest match rates outside the US. We provide automated ID verification through our advanced ID validation systems that have access to global government and non-governmental databases.
Pairing IDMscan with IDMdevice allows for easier mobile ID verification through device fingerprinting with real-time identity verification. Document verification services make customer onboarding faster and smoother. Get quick international ID card verification in seconds. Going global has never been easier with IDMERIT.
Behavior Monitoring of Rotating Compliance Personnel
Alternating personnel seems like a fabulous idea, in theory, however, in execution there could be some potential hiccups. In best practice, this personnel would be randomly switched in order to prevent any money laundering shenanigans. In reality, there is the question of where the replacement will be coming from and how will you choose the replacement.
Hiring a lot of compliance staff to sit around waiting to be changed isn’t feasible and neither is moving them to different branches or departments without behavior monitoring. Behavior monitoring can also be used as part of AML screening solutions, user and customer onboarding best practices. The use of behavior monitoring during the hiring and personnel rotation makes it easier for your HR department to select the right person as your compliance officer.
Using AI in Risk Assessment, Transaction, and Watchlist Screening
You cannot have an anti-money laundering solution without enhanced due diligence that caters to stringent risk assessment, transaction, and watchlist screenings. Once your AML screening solutions don’t have access to over 2000 watchlists then what you have is an open-door policy, not an anti-money laundering solution. Risk assessment, transaction monitoring, and watchlist screening are crucial to your anti-money laundering solution.
Incorporating machine learning technology in our IDMtrust API allows us to assess your customers’ risk scores in record time. We check devices, emails, IP addresses, and past online activity to give you the best view of your potential customer. Our watchlists include CIA’s Politically Exposed Persons (PEP’s), US Immigrations and Customs (ICE) Most Wanted, US Treasury Office of Foreign Assets Control (OFAC)
Specifically Designated Nationals (SDN’s) and the UN’s Security Council Consolidated Sanctions (UNSC List). We even include relations to PEP’s, spammers, and Special Interest Persons (SIP) who were previously implicated in fraud, terrorism, corruption, financial, and organized crime.
Digital Identity Management Services
The government is one of the entities with the lowest trust factors because who can you complain to when it’s the government doing you wrong. Can you really rely on a government database to protect your data when they are hacked more than anybody? Though there are provisions for increased cybersecurity for government databases, implementation of digital identity management may come too late for you and your customers.
Private ownership with government oversight is a better option that you can rest easy with. Though FinCen has its head in the right direction, centralizing all that financial industry data is like waving a red flag at the cybercriminals while dancing in a red dress. They will come and you won’t have time for FinCen to fix operational hiccups and personnel leaks. Forget their future plan and invest now in digital identity protection. Protect your digital identity with digital identity management services from IDMERIT.
Financial Industry Expertise Working for You
As noted previously, the finance industry is where the need for AML compliance began. Banks and financial institutions are always the first to adopt any changes to AML compliance regulations. With years of experience providing AML compliance solutions for banks, we have the industry expertise to develop and help you implement effective AML screening solutions that will seamlessly blend with customer onboarding best practices.
Automated ID verification with real-time identity verification is part of our digital identity services that are designed for global AML compliance. Considering the BSA’s move into the arts and antiquities industry, as an organization within that market, you will need digital identity management services that know how to adapt and create AML compliance solutions just for you. Being new to AML compliance and with your own global reach, you need global expertise at your side with strategic partnerships within the financial industry to ensure you pass your first AML screening flawlessly.
Closing
It is good to see FinCen and other regulatory bodies making strides towards improved anti-money laundering solutions. While they set the guidelines, at IDMERIT we know it is up to us to see the effective implementation of their AML policies to fruition. Though they are now taking their first tentative steps towards complete automation of global ID verification, we have already gone beyond automated ID and ID validation into behavior monitoring, mobile ID verification, and even real-time identity verification on social media.
Global ID verification should have always been a part of customer onboarding best practices for global industries. And for our IDMERIT clients and partners, it is already the norm. Right now, as part of their ID validation systems, they can get customer risk scores, identify persons from over 2000 watchlists, document verification services, and still provide a smooth customer onboarding experience even when onboarding beneficiaries and corporate clients. Adapting to the new BSA mandates is super easy, and barely an inconvenience with IDMERIT.
Talk to us today about your BSA concerns and improving your AML compliance solutions.
