Main Content

AML/CFT, Bank Secrecy Act and Sanctions

  • Strengthening the Risk-Based Approach

    Bob Werner, and Sabreen Dogar

    The AML risk-based approach is extremely useful, but regulatory, media, and budget pressures have hurt its implementation and effectiveness on many levels.
  • Designing a New AML System

    Juan C Zarate, and Chip Poncy

    There is growing recognition that the existing AML/CFT regime isn’t working as intended. Now is the time to rethink and rebuild a system to meet today’s growing demands.

  • Global Banking's Blindspot: SARs

    Alaina Gimbert

    Financial institutions serve as the gatekeepers of the financial system and report suspicious transactions and activities to government authorities. However, rules limit a bank’s ability to share SARs within its own organization, which limits a firm’s ability to uncover illicit activity. TCH requests that FinCEN issue additional guidance on sharing of information with branches and foreign affiliates.