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News & Views

The CLEAR Picture

May 2016 edition

In this issue

Featured insight


Martin WoodsThe Word with Woods: The future of AML
The CLEAR Picture is proud to introduce “The Word with Woods,” a column from Martin Woods, an AML professional and thought-leader on global anti-money laundering practices. In his initial column, Woods looks into his crystal ball to envision what the future of AML might look and how professionals of today can prepare for it.
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Best practices


coins stackedRegulatory change and the cost of compliance
The speed and sheer breadth of regulatory change is an ever-present challenge for firms. To say that regulators around the world have been prolific in their policy pronouncements following the financial crisis puts it mildly. Firms don’t have a choice but to track, analyze, and assess the impact of regulatory change, despite the fact that these are exceedingly resource-hungry endeavors.
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Michele SullivanGetting started with third-party risk management: Two key questions
Banks often outsource technology services to third-party vendors. In light of increased regulatory attention and third-party involvement in day-to-day business operations, many bank boards and senior management teams are considering their approach to developing a third-party risk management program. A thoughtful approach based on an initial assessment of the bank’s current state can result in better, less burdensome risk management and compliance.
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moneyCreating a first line of defense against AML
In simple terms, any risk assessment around money laundering can be boiled down to three crucial questions: Is a person who they say they are? Can you do business with them? Should you do business with them?
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Spotlight


Sylwia WolosKnow your ultimate beneficial owner or face the consequences
The fight against money laundering and corruption has made financial transparency a global priority, meaning it is critical that we know with whom we are doing business. Entering into a contract or business relationship with a company without full knowledge of beneficial ownership, past or present, introduces significant risk to an organization. Even an unwitting contravention of anti-money laundering, anti-corruption, and bribery legislation can have extreme consequences through regulatory censure, financial penalties, and reputational damage.
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Regulatory Trends


Jeremy ByellinCFPB action underscores agency’s proactive and expansive regulatory approach
At the beginning of 2016, the Consumer Financial Protection Bureau (CFPB) announced its consent order against Dwolla, Inc., an online payment service. The CFPB claims that this enforcement action is due to Dwolla’s “deceiving consumers about its data security practices and the safety of its online payment system.” This signals that the CFPB seems to be a new breed of regulatory animal – one that seems to execute its responsibilities with a sense of vigor not seen in other agencies.
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