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)

Bi-Annually10% (19)

Annually59% (109)

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

Yes42% (101)

No58% (141)

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

Yes78% (57)

No22% (16)

Do you plan on attending FinCEN’s hearing on its Customer Due Diligence proposal? July 13 - July 27

Yes29% (25)

No71% (62)

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

Effective41% (124)

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)

Training5% (10)

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

Yes27% (15)

No73% (41)

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

Yes73% (145)

No27% (54)

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

Yes64% (50)

No14% (11)

Undecided22% (17)

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

Fraud16% (52)

Sanctions14% (47)

Corruption5% (17)

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)

Decrease15% (23)

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

Yes13% (10)

No87% (68)

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

Yes69% (54)

No31% (24)

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.