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How to add predictive analytics into your risk program. Risk reports are often limited to historical insights and issues and do not provide guidance and insights into the future of the organization. Adding predictive analytics can allow your organization to detect emerging risks and create mitigation plans. This can be achieved by combining internal and external key risk indicators (KRIs) and key performance indicators (KPIs) with regulatory intelligence. This ensures that risk reports can detect more issues and highlight areas of concern. Click here to learn more.


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09/24/2019

Reminder of annual blocked property report

OFAC has posted a reminder of the requirement to provide OFAC with an Annual Report of Blocked Property (ARBP). Persons subject to this reporting requirement must submit a comprehensive report of all blocked property held as of June 30 of the current year by September 30. For more information see the OFAC Guidance on Filing the Annual Report of Blocked Property.

09/24/2019

Ohio bank reports counterfeit cashier's checks

The OCC has issued an alert concerning counterfeit cashier's checks using the routing number of Consumers National Bank, Minerva, Ohio. The checks are being presented to the bank for payment in connection with a variety of online auction overpayment and job opportunity scams. For details, see BankersOnline's Alerts and Counterfeits post.

09/23/2019

Major funding sources for Iran's terrorism targeted

The Treasury Department announced on Friday that OFAC has designated the Central Bank of Iran, the National Development Fund of Iran (NDF), and Etemad Tejarate Pars Co.

Iran’s Central Bank has provided billions of dollars to the Islamic Revolutionary Guards Corps (IRGC), its Qods Force (IRGC-QF) and its terrorist proxy, Hizballah. Iran’s NDF, which is Iran’s sovereign wealth fund and whose board of trustees include Iran’s president, oil minister, and the governor of the Central Bank, has been a major source of foreign currency and funding for the IRGC-QF and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). Etemad Tejarate Pars is an Iran-based company that is used to conceal financial transfers for MODAFL’s military purchases, including funds originating from the NDF.

For additional identification details, see BankersOnline's OFAC Update.

09/20/2019

OCC announces enforcement actions

The OCC has released a list of recent enforcement actions taken against individuals now or formerly affiliated with OCC-supervised institutions:

  • A Notice of Charges for an order of prohibition was issued against a former teller of PNC Bank, Wilmington, Delaware, who misappropriated cash from his teller drawer and a ATM, over both of which he had sole control. The Notice announces the OCC’s intention to issue the order of prohibition, subject to the respondent’s right to an administrative hearing of the OCC’s charges.
  • Removal and prohibition orders were issued to:
    • a former teller of The Huntington National Bank, Columbus, Ohio, whom the OCC found to have misappropriated a total of $11,000 in cash while clearing customer cash deposits from ATMs and falsified general ledger tickets to conceal the misconduct
    • a former loan officer of The City National Bank and Trust Company, Lawton, Oklahoma, whom the OCC found to have submitted false or misleading information related to eight loans totaling $7,081,446 from four financial institutions, causing those institutions to lose the total value of the loans. The former loan officer pled guilty to one count of fraud and one count of wire fraud and agreed to pay restitution of $7,081,446 to the four financial institutions.
    • a former phone banker of Wells Fargo Bank, National Association, Sioux Falls, South Dakota, on the basis of activities while serving as a phone banker . The OCC found that the former banker provided bank customers’ credit card numbers to unauthorized individuals who fraudulently used the information, causing a loss to the bank of approximately $7,975.
    • a former branch associate of Capital One, National Association, McLean, Virginia. The OCC found that the former banker assigned temporary debit cards to two customers' accounts without their permission and withdrew a total of $22,606.50 at automated teller machines using the cards.

09/20/2019

Changes to FDIC post-exam survey process

In FIL-50-2019 the FDIC is notifying FDIC-supervised financial institutions that the Office of the Ombudsman, which is independent of the supervisory process, reports directly to the FDIC Chairman's office, and is a confidential resource for banks, is now administering the Post-Examination Survey process.

The Office of the Ombudsman will:

  • Assume responsibility for soliciting Survey responses effective October 1, 2019;
  • Send notice that the Survey will accompany the Report of Examination;
  • Provide a reminder to encourage participation in the Survey; and
  • Serve as the contact point for banks regarding the Survey and follow-up requests.

The FIL includes links to the current post-exam survey questions for the Safety and Soundness and the Compliance and CRA exams.

09/18/2019

Treasury proposes FIRRMA regs

The Treasury Department announced yesterday it has issued two proposed regulations to comprehensively implement the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) and to better address national security concerns arising from certain investments and real estate transactions. The regulations strengthen and modernize the Committee on Foreign Investment in the United States (CFIUS), an interagency committee authorized to review certain transactions involving foreign investment in the United to determine the effect of such transactions on the national security of the United States.

Comments on the proposed rules will be accepted through October 17, 2019. Treasury intends to issue final rules to take effect no later than February 13, 2020.

09/18/2019

OFAC targets Alex Saab network in Venezuela

The Treasury Department announced yesterday that OFAC has designated three individuals and 16 entities for their connections to Alex Nain Saab Moran (Alex Saab) and his business partner, Alvaro Enrique Pulido Vargas (Alvaro Pulido), who have enabled former President Nicolás Maduro (Maduro) and his illegitimate regime to corruptly profit from imports of food aid and distribution in Venezuela. The individuals designated include Alex Saab’s two brothers, Amir Luis Saab Moran (Amir Saab) and Luis Alberto Saab Moran (Luis Saab), as well as Alvaro Pulido’s son, David Enrique Rubio Gonzalez (Rubio). The 16 entities designated are owned or controlled by the aforementioned individuals or Alex Saab himself.

As a result of these actions, all property and interests in property of the individuals and entities designated yesterday, and of any entities that are owned, directly or indirectly, 50 percent or more by those individuals or entities, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property of blocked or designated persons. For identity information on the designated individuals and entities, see BankersOnline's September 17, 2019, OFAC Update.

09/17/2019

Maryland insurer settles Kingpin Act violations claims

OFAC has announced that Atradius Trade Credit Insurance, Inc. of Hunt Valley, Maryland, a trade credit insurer licensed to operate in the state of Maryland and a subsidiary of Atradius N.V. ATCI, has agreed to remit $345,315 to settle its potential civil liability for two apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations by dealing in property or interests in property of a specially designated narcotics trafficker.

09/17/2019

FinCEN makes CTR FAQ change (updated)

Thanks to a post in BankersOnline's BSA/AML/CIP/OFAC discussion forum by one of our newest users, we've learned that FinCEN has updated its FAQ document on CTR filing to change the answer to Question 16 concerning transactions in which the conductor has more than one role. The change was made without public announcement, although there may have been a notice behind FinCEN's e-filing login wall..

Current instructions for the CTR indicate that when a conductor completes a currency transaction on the conductor's own behalf and on behalf of another person (e.g.,a business owner depositing a reportable amount of cash to a personal account and to an entity business account), the reporter completes one Part I for the conductor and checks the first "role" in item 2 that applies, starting at the left. That would be check box 2a, indicating a transaction conducted on behalf of oneself. The total amount is reported in that Part I entry.

Apparently, FinCEN would like such a CTR completed differently. Question 16 in the FAQ now says that there should be two Part I entries for the conductor -- one with item 2a checked for the transaction "completed on own behalf" (the deposit to the personal account) and the other with item 2b checked to report the part of the transaction conducted on behalf of another (the business). And of course, there is still the Part I entry for the business with item 2c checked (person on which behalf transaction was conducted).

The discussion thread indicates FinCEN's Help Line says the change won't be enforced until the instructions are updated and more formal guidance provided. FinCEN should also review its response to FAQ question 22 before finalizing those instructions and guidance. But, of course, none of this comes straight from FinCEN.

UPDATE (9/18/2019): We've learned (and verified) that FinCEN has restored the answer to Question 16 in the FAQ to conform to the instructions on the current version of the CTR.

09/16/2019

OFAC targets N Korean cyber hackers and Ugandan top cop

The Treasury Department issued two news releases on Friday concerning OFAC actions. OFAC designated three North Korean state-sponsored malicious cyber groups responsible for North Korea’s malign cyber activity on critical infrastructure to support illicit weapon and missile programs. This activity included tactics such as cyber espionage, data theft, monetary heists, and destructive malware operations targeting government, military, financial, manufacturing, publishing, media, entertainment, and international shipping companies, as well as critical infrastructure.

OFAC also sanctioned the former Inspector General of Police of the Ugandan Police Force, Kale Kayihura, pursuant to Executive Order 13818, for having engaged in serious human rights abuse against Ugandan citizens, as well as for his involvement in corruption.

For identification information on the entities and individual designated by these actions, see BankersOnline's OFAC Update.

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