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Foreign-issued prepaid cards are:
Apr 15 - May 17
High risk89% (571)
Low risk2% (16)
Medium risk 7% (45)
Not sure2% (10)
Does your institution have the proper IT measures in place to prevent or mitigate a cyberattack aimed at stealing proprietary data or money directly from accounts?
Mar 22 - Apr 15
Yes 59% (72)
No 9% (11)
Not sure 24% (30)
Somewhat 8% (10)
Does your company sanction screen the payee of official checks?
Feb 22 - Mar 22
cashier’s checks44% (66)
treasury checks11% (17)
money orders 12% (18)
don’t know33% (50)
Has transparency in cover payments increased since the introduction of form MT 202 COV?
Jan 29- Feb 22
The form has increased transparency.36%
The form has not increased transparency.32%
The form has been somewhat effective since not all financial institutions use it. 26%
I'm not sure.5%
Risk Assessments are an essential part of any financial institution's AML procedures. My FI's risk assessment is updated:
Jan 10- Jan 28
Monthly 12% (22)
When events warrant (e.g., new products)18% (34)
What will be the biggest challenge for AML professionals in 2013?
Nov 30- Jan10
Regulatory expectations 42% (152)
Expanding scope of duties17% (60)
Not useful20% (72)
Retaining and/or hiring qualified staff21% (75)
How useful will FinCEN's BSA IT Modernization Program be once it is completed?
Sep 24- Oct 11
Very useful 51% (35)
Somewhat useful14% (10)
Not useful7% (5)
Don’t know28% (19)
The events of September 11th brought rapid changes to financial regulations worldwide, but were those changes generally the correct ones or should legislation have followed a different path?
Sep 11 - Sep 24
Yes, the regulations were appropriate. 64% (52)
No, changes were needed but the laws should have addressed different financial activities.36% (29)
Do you think that the New York State Department of Financial Services accusations against Standard Chartered Bank will eventually be shown to be overzealous?
Aug 14 - Sep 11
The U.S. Department of the Treasury published a model agreement (with France, Germany, Italy, UK and Spain) to implement the information reporting of FATCA. Do you agree with this approach?
July 27 - Aug 13
Do you plan on attending FinCEN’s hearing on its Customer Due Diligence proposal?
July 13 - July 27
In February, the Internal Revenue Service issued Foreign Account Tax Compliance Act (FATCA) proposed regulations, which aim to require non-U.S. based financial institutions to report directly to the IRS information about financial accounts held by their U.S. taxpayer clients, among other things. A good portion of the proposed regulations were intended to address industry concern regarding complexity and depth of the requirements and, cost burden. Do you believe the proposed regulations addressed those implementation issues?
Apr 11 - May 22
Yes, I believe the proposed regulations have eased the burden for foreign financial institutions' implementation of FATCA.17% (10)
No, I don’t believe the proposed regulations have eased the burden for foreign financial institutions' implementation of FATCA. The challenges, such as cost of implementation and complexity, remain the same.49% (29)
I believe the proposed regulations have eased the burden of implementation in some areas and, increased the burden of implementation in other areas.14% (8)
I'm not sure.20% (12)
How likely are you to call or directly contact law enforcement about a suspicious activity report (SAR) you filed on a client or transaction that feel you is particularly suspicious or egregious?Mar 23 - Apr 11
I have already informed law enforcement in the past about a SAR I filed. 52% (77)
I have never directly contacted law enforcement about a SAR I filed. However, if I felt that a particular SAR needed immediate attention, I would not fail to contact them. 35% (52)
It never occurred to me to call law enforcement about the filing of a SAR. 9% (13)
I would not feel comfortable contacting law enforcement about the filing of a SAR. 5% (7)
The U.S. Department of State released the latest version of its International Narcotics Control Strategy Report (INCSR) on March 7. The report lists major money laundering countries and includes country-to-country analysis of certain anti-money laundering regimes. How useful are these reports to compliance officers?Mar 14 - Mar 23
The reports are very useful. I use the reports to assist my financial institution in its development of country risk analysis, training, or for other purposes. 44% (18)
The reports are somewhat useful. A lot of the information, such as its list of major money laundering countries, is well known to most compliance officers or, I find a lot of the information repetitive.29% (12)
The reports are not useful. The information does not pertain to my particular financial institution or I find the information to be too general. 7% (3)
I am not familiar with the reports. 20% (8)
On February 16, the Financial Action Task Force announced its revised Recommendations and added tax crimes as a predicate money laundering offense. In your opinion, once that change is incorporated into your jurisdiction's laws how will that affect your compliance program?Mar 1 - Mar 13
The additional compliance demands will translate into the need for more resources, such as staff and a larger budget. 38% (36)
I don't anticipate any great changes. 31% (29)
Tax crimes are already a predicate money laundering offense in my country. 22% (21)
Not sure. 9% (8)
President Obama recently signed a budget defense bill that will block foreign banks that “knowingly” facilitate the purchase of oil through the Central Bank of Iran (CBI) from the U.S. financial system. Will the law be:Jan 18 - Feb 29
Note Sure26% (78)
Not Effective33% (99)
As you prepare for 2012, the biggest challenge to the AML community is:Dec 19 - Jan 17
Adequate Resources24% (51)
Responding to Regulatory Examinations8% (16)
Understanding how various products are used for money laundering12% (25)
All of the above51% (107)
Are broker dealers ready for the July enforcement deadlines of two sets of federal rules that will broadly expand their know-your-customer duties?Nov 30 - Dec 19
Have you followed FinCEN's proposed new SAR Form? If so, do you:Nov 17 - Nov 30
Support 32% (16)
Oppose 34% (17)
Need More Time to Review 34% (17)
October 26 marks the ten year anniversary of the USA PATRIOT Act. Has it made us safer?Oct 27 - Nov 17
Do you agree with FinCEN’s final rule to implement section 104 (e) of the Comprehensive Iran Sanctions, Accountability and Divestment Act (CISADA)?Oct 10 - Oct 26
What percent of your SARs/STRs are originally sourced by your:Aug 31 - Oct 10
transaction monitoring system(s)59% (27)
list-screening system(s)9% (21)
front-line employees noting suspicious activity26% (26)
other 6% (18)
AML duties seemed to have greatly expanded in recent years, but have they throughout the industry? In your current AML role are you also responsible for:Jul 6 - Aug 30
All three 58% (190)
None of the above7% (22)
At last week's ACAMS European Conference, many government officials expressed support for requiring financial institutions to monitor domestic PEPs.
Today, do you monitor activities for domestic PEPs? Jun 17 - Jul 6
Yes 61% (86)
No 39% (54)
Should countries develop AML regulations to track and prosecute the use of the Internet to move illegal proceeds? Jun 6 - Jun 17
Yes 97% (126)
No 3% (4)
Are your regulatory examiners formally recommending increased board of directors’ involvement in compliance-related decisions?May 20 - Jun 6
Yes 74% (51)
No 26% (18)
With the death of Osama Bin Laden, will the threat of terrorist financing:May 6 - May 20
Increase 85% (132)
View the discussion.
Do you have a cybersecurity program that formally includes the AML division?Apr 26 - May 6
Identity theft14% (3)
Credit card fraud86% (18)
What is the most common risk your financial institution has faced when providing the prepaid card product to customers?Apr 11 - Apr 26
Identity theft24% (21)
Credit card fraud16% (14)
Income tax evasion 6% (5)
Money laundering 43% (37)
Terrorist financing activities10% (9)
There have been reports that FinCEN is proposing to severely limit or eliminate state access to BSA Data.State officials indicate that this would severely hamper money laundering investigations. Do you support FinCEN's proposal? Feb 27 - Apr 11
If the States do not have access to the BSA data, do you think it will have an impact on your AML program?Feb 27 - Apr 11
If so, why?Feb 27 - Apr 11
- Additional reporting requirements will certainly be implemented.
- State access to BSA data allows opportunity for region specific training, and supports state and regional collaborations, task forces and awareness groups.
- FinCEN is a middle man. The information belongs with all law enforcement authorities. It's federal thinking like this that contributed to 911.
- Less likely our SARs will be used to facilitate investigations and catch bad guys.
- More law enforcement requests.
- unable to actively identify money laundering in a timely manner.
- States may require an alternate filing of the similar activity filed with fincen (duplicate reporting?)
- One would want to look at the SAR and STR to assess money laundering vulnerability.
- There is already concern that it is challenging for law enforcement to sort through all of the reported data and take action. If access is limited then it is possible that reporting will not be effectively used and acted upon.
- slow and ineffective unnecessarily due to no access
- It would be less stressfule if the state don't have the BSA/AML info of the institutions. Especailly for the audit.
- every state most comply for the interest of moving the banking industry forward
- This would create severe impediments to the depth and efficiency of investigations at the state and local level. It would also put huge operational and financial burdens on banks.
- Access to banking transactions and ongoing transaction monitoring assist AMLRO in conducting and supporting investigations; if no access to information obviously it will create hurdles in FI AML programs
- I believe this will require duplicate reporting to the federal government and to the individual State governments.
- Less data available could adversely impact case decisioning and consequently delay the process of 'catching the bad guy'.
- Inconvinience the investigative portion
- Too few people have access now. More restrictions mean FinCEN stores data for data's sake. When more enforcement is badly needed there will be little to none.
- Anticipate unnecessary subpoenas for information that could have readily been gained by viewing BSA data.
- FinCEN's proposal to restrict state and local law enforcement access to BSA data to state coordinators only is shifting the financial burden from the federal level to the states. This obviously has a huge negative impact to state and local LEAs, but it would also impact my AML program. With limited or no access, states may begin to impose separate reporting requirements. This would add to compliance burdens of SAR filers and could be confusing when operating in multiple states. Additionally, this complicates the somewhat recent expansion of 314(a) powers to state and local LEAs. How would FinCEN facilitate 314(a) requests for non-federal LEAs if those same requestors were prohibiting from accessing BSA data? In general, this could confuse SAR filers to whether they are permitted to release SARs to state and local LEAs. Overall, how does restricting or eliminating access to SAR data encourage information sharing to connect the dots and detect criminal activity sooner?
- I believe the states should have access to review information that could aid in their investigations. They can determine when reviewing CTRs or SARs if they need to obtain additional documentation from the bank. Without access to that data, either the state investigators would not know what they are missing or an extra burden would be placed on the financial institution when approached as to what they should or should not provide.
- duplicate reporting, expense increase.
- States will most likely enact separate legislation to require this data. The states will not all have the same documentation requirements which will require us to have to be able to fulfill different requirements for each state in which activity occurs.
Which section of the ACAMS web site
do you find the most useful?Feb 26 - Mar 7
Publications (ACAMS Today and Connection)7% (15)
Member profiles31% (67)
Chapter pages9% (19)
Conferences and Events27% (59)
A recent report found that 63 percent of 500 respondents dropped an account or severed business ties over FCPA or OFAC concerns in the last 3 years.
Have you in the past year: Feb 14 - Feb 25
Dropped an account due to FCPA concerns15% (4)
Stopped a merger due to OFAC compliance concerns4% (1)
Not been affected by OFAC or FCPA concerns81% (21)
How would you rate your relationship
with your local law enforcement? Jan 21 - Feb 14
Excellent 48% (53)
Good 32% (35)
Room for Improvement11% (12)
What will be your biggest challenge for 2011? Dec 3 - Jan 21
Training of staff 10% (28)
Staying on top of emerging risks21% (59)
Regulatory oversight14% (39)
All of the above55% (153)
There has been a global increase in awareness on the crimes of human trafficking and smuggling. Would your institution be interested in ACAMS providing information on Nov 9 - Dec 3
Red flag transaction indicators 19% (24)
Human trafficking typologies6% (8)
Case studies6% (8)
All of the above68% (88)
How many AML related staff do you have in your financial institution?Oct 22- Nov 9
50 or more 25% (44)
25 to 508% (15)
10 to 258% (14)
10 or more4% (8)
0 to 1055% (98)
What hot topics would you like FATF to cover during their October Plenary and Working Group Meetings?Oct 12- Oct 22
Typology report on money transmitters 29% (13)
Hedge Funds18% (8)
An updated PEPs report13% (6)
Sanctions and Compliance27% (12)
Updating the jurisdictions with AML/CTF deficiencies13% (6)
The US Treasury’s FinCEN has announced a proposal to report “cross border wires.” Do you plan to file a comment letter?Sep 29 - Oct 12
The US Treasury’s FinCEN has announced a proposal to report “cross border wires.” Do you plan to file a comment letter?Sep 13 - Sep 29
One - Five38% (39)
Six - Ten15% (15)
10 or more43% (44)
AML Training for My Institution/Organization/Agency
includes coverage of:Aug 28 - Sep 13
Money Laundering Laws & Regulations24% (13)
Financial Crime4% (2)
Corruption and Bribery0% (0)
All of the Above71% (39)
What is the most challenging area for regulated entities? Aug 13 - 27
Staying current with new AML trends41% (29)
Resource support from senior management37% (26)
Retaining top talent21% (15)
In 2010, what has been your biggest challenge? Jul 22- Aug 12
Financial Crime17% (55)
Money Laundering27% (88)
All of the above39% (126)