Yes, I know this is from a vendor, but there is still some good information on this site.

http://tinyurl.com/355cltw

My only nitpick is that they use the acronym KYC ("know your customer")...BSA Examiners recommended we remove references to KYC from our policies and procedures and more correctly cite customer identification program and customer due diligence...just an observation.

It's a global organization. In many countries they still call it KYC. There is a section on the site for due diligence. The site is still a good resource. You might also notice that they spell "organization" "organisation", but I don't see that as a big problem.

The FDIC is still smarting from its foray into the world of KYC. Back when regulators first proposed a "know your customer" regulation -- prior to 9/11 and the USA PATRIOT Act -- "prehistory" to some of you -- the agency took a huge negative hit from the American public, who were adamant about not having their private personal information shared. The FDIC got the huge majority of the comments, and at the time it set a record for the shear numbers of comments ever received.

What the public now endures -- CIP is the tip if the iceberg -- with CDD and transaction monitoring for money laundering and terrorist financing activity is far more invasive than was proposed back then.

Sure, it's KYC wrapped up in pretty paper and a bow, but here in the U S of A it goes under one or more aliases.

I'm not arguing that the site is a good resource. On the contrary, it has some very good information and I'm keeping it bookmarked. I'm just cautioning about the use of KYC in any of your policies and procedures.

And I wasn't arguing for either side, just trying to add some historic reference to the year that bank customers told the FDIC that "KYC" was "chicken-XXXX."

I remember the whole KYC bru-ha-ha. And when it went down in flames, to think that most of us thought our biggest problem was going to be Y2K.

**sigh**

I've read his section "Confessions of a money launderer" where he describes how he went from helping customer launder money to compliance officer. Very interesting...

I worked at a large East Coast bank in the mid-90s where the Fed (our holding company regulator) actually wrote us up because they were at an Edge office and inquired about our KYC policies! No one knew what they were talking about. They cited it in an exam. We gathered up all of our online policies and procedures that related to knowing our customers, understanding our borrowers, types of ID required, background checking, etc. and linked them to a one paragraph statement on KYC. The Fed was happy.

I guess you could call those "The Good Old Days"

Breaking news:
As of 3/9/99 over 225,000 objections to KYC have been filed with the FDIC

(1/27/99): FDIC and the American Bankers Association express opposition to KYC

(1/28/99): American Bankers Association calls for withdrawal of KYC proposal

(1/29/99): News media reports on opposition to KYC

Good Guys Win One - banking committee bill would kill KYC

FLorida Lilly: Where is this confessions of a money launderer???

Of course they back-doored the whole KYC process into the interagency examination manual without legislation or regulation, so who won????

I'm not Florida Lilly, but go to the site and click on "Home". You will see the link on the left side of the page that will take you to "confessions".

Thanks for sharing the link. I have been viewing that website for a couple of years. He has some very interesting insite to global CIP and risk ratings of high risk countries.

I too have read several of the things on that website. I agree with Florida Lily, the "confessions" are an interesting insight into professional money laundering.

I'm torn on this whole 'confessions of a money launderer' thing. For the same reasons that I'm on the fence about Michael Vick getting this year's MVP.

Does being a criminal uniquely qualify someone in being an expert in the crime they committed? Granted the guy probably served his time or whatever, but on the other hand I spend my days attempting to protect our Bank from criminals....

I think world-check over plays this guy. I don't think I learned anything I didn't already know from reading the material published by FATF, FINCEN, or by reading a Mark Bowden book, and this company - who mind you we pay to help us comply is making this guy (who probably caused other compliance officers like myself a lot of annoyance not too long ago) some sort of celebrity which I think needs to be wound down just a bit.

We will do our best to put the MVP in Tom Brady's hands, although last night's game was a real tense session.

Last night's game was such a disappointment. Was so happy to see Flynn carry the Packer torch while Rogers is mending. Darn Patriots anyways .... grrrrrr


MVP should go to Rogers

;-) Amen, John.