ACAMS Las Vegas got off to a nice start with keynote speakers Angela Byers, Financial Crimes Section Chief of the FBI, Criminal Investigations Division, and Peter T. Edge, Executive Associate Director of Homeland Security Investigations. The day was filled with a number of great talks, but two sessions stood out to us as particularly relevant:

Peter Harrell- Deputy Assistant Secretary for Counter Threat Finance & Sanctions

“I want to thank the private sector for your AML Tools and systems- which contribute directly to the protection and safety of the United States”

Considering we just released our revamped Sanctions Screening program yesterday, Peter Harrell’s talk was an interesting and timely reminder of the real purpose behind anti-money laundering and sanctions screening. Thanking the crowd for its contributions to the continued safety of the United States, Harrell described anti-money laundering and the individuals responsible for it as, “the pointy end of the spear protecting citizens in the US,” and was adamant about the real importance of anti-money laundering in disabling international threats and terrorist groups.

He went on to describe the history of economic sanctions as one of the earliest forms of international relations, dating back to Athens, which used sanctions against Megara to avoid a direct war with Sparta.

According to Harrell, sanctions have since evolved over the past 2 millenia, and even into the last 2 decades to become more effective and targeted tools than ever before. As a sanctions screening technology provider, we’re well aware of the complexities this entails, and so are our clients. The world is now more tied together than ever before, providing new opportunities for violators to slip through or avoid sanctions. Instead, our screening product allows merchants, banks, money services businesses, virtual currency exchanges, and financial institutions, to easily and effectively screen against sanctions lists, allowing for the more targeted capabilities Harrell describes, and preserving the effectiveness of economic sanctions as a powerful tool for international relations.

We’re proud to contribute to the effectiveness of these tools by providing financial institutions with the capabilities they need to accurately evaluate sanctions matches and screen against international sanctions lists.

Read more information about our latest Sanctions Screening capabilities here.

Refinining SAR Investigation Techniques and Aiding Law Enforcement

The latest update to the IdentityMind Global Fraud & Risk Management Platform improved our Anti-Money Laundering capabilities with the addition of automatic SAR filing, allowing compliance officers to file suspicious activity reports directly from our platform.

However, after filing a SAR, many financial institutions never receive a response, which can lead to little feedback on how to improve reports for Law enforcement. This session provided a rare look from the Law Enforcement perspective. Some of the key points for SAR filers were:

– Keywords (use varying terms)- often, terms have different meanings according to the industry they refer to, which can be difficult or misleading for Law enforcement.
– Inclusion of Remote Access Account Information (IP Address, Telephone Numbers, etc.)
– Reported Activity does not appear to support established business practices
– Financial loss to financial institution
– Existence of a suspected shell company
– Is law enforcement already involved?

The most relevant reminder therefore was the importance of the why and how in a report- why the report was filed, and how the institution was used to facilitate suspicious activity. The addition of a strong impact statement to catch the eye of law enforcement, can also make a significant difference. As many departments are in fact overloaded with SAR reports, an impactful statement can ensure that the report actually grabs the attention of law enforcement.

Our clients control the content of the Suspicious Activity Reports, our Platform facilitates the process by automatically populating most of the form with the actual transactions and details of suspicious activities, leaving the narrative (the why and the how to the analysts). Once the report is finalized, analysts can file it to FinCEN through our interface.

Overall, ACAMS has been a refreshing reminder of the genuine effort and purpose behind Anti-Money Laundering efforts. The significance of AML often gets lost behind the headlines of large fines or regulatory changes, but anti-money laundering isn’t, and shouldn’t be done simply for the sake of avoiding fines or to comply with regulation- but to continue to disable some of the most dangerous criminal organizations world wide, including organized crime, human trafficking, and terrorist organizations.