Blog

Financial institutions sending large denomination U.S. currency to its Mexican affiliates or correspondent banks should raise a question in the minds of the institution’s compliance staff.

Training should encompass information related to applicable business lines, as well as changes to internal policies, procedures, processes, and monitoring systems.

The U.S. enacted a new law named the Anti-Money Laundering Act of 2020 (AML Act) that includes provisions that have a long-arm jurisdiction and can impact foreign financial institutions. 

Banks offering account services to processors should assess the risks associated with these customers, by considering the following:

A risk factor when dealing with bulk cash shipments is knowing the true origination of the cash.

Without a general understanding of the BSA, the board of directors cannot adequately provide BSA/AML oversight; approve BSA/AML policies, procedures, and processes; or provide sufficient BSA/AML resources.

Thorough paper trail equals transparency

The bank’s AML compliance officer should have ready access to the bank’s board of directors.

An effective BSA compliance program would entail allowing a BSA compliance officer to have direct communication with the members of a the board of directors.

Consolidated information assists senior management and the board of directors in understanding and appropriately mitigating risks across the organization.