Information Sharing—Strengthening our AML/CTF Program
Author: Richard T. Wells, CAMS-FCI
The focus of this paper is to leverage the USA PATRIOT Act Section 314(a) and (b), and to improve the reader’s anti-money laundering/counter-terrorist financing (AML/CTF) program with a focus on the importance of not just building but maintaining relationships with law enforcement (LE) and regulators. The goal is to display the importance of information sharing between financial institutions (FIs), as well as between LE, regulators and FIs, specifically pertaining to financial intelligence in connection with money laundering and/or terrorist financing investigations. This will be accomplished by defining the USA PATRIOT Act Section 314(a) and (b) and by emphasizing what the current state is. A redacted case example that spanned two years and uncovered a large network of trade-based money laundering (TBML) and Black Market Peso Exchange (BMPE) will be showcased. The data and information gathering (research) of this white paper will be from the laws and regulations, as well as the professional organizations/groups that have written on this topic.