The next wave of billion dollar fines is underway
as authorities are coming to the banks, already
armed with evidence of KYC, AML and CFT
systemic failings due to the way international
money transfers flow through correspondent
banks. This growing evidence shows how
money launderers’ businesses are successfully
laundering over a trillion dollars a year by
circumventing the controls of banks across the
world.
Good day all,
Please find attached the June 2017 edition of our very informative Newsletter.
We look forward to your continuing support and comments. Please send all comments and suggestions to training@kawmanagement.com or training.kawmgmt@candw.ag.
Happy reading
Learn about how remittance challenges have grown as electronic payment usage has continued to grow. Learn about how the movement to electronic payments and remittances has created benefits for accounts payable but created a cash application challenge for those in accounts receivable. Created by Centreviews Business Intelligence Suite.
CPAs responsibilities to detect fraud in audits, required approaches, types of financial statement frauds and specific case examples of different types of financial statement fraud
Learn the basics of credit in this easy-to-follow, introductory course that includes:
- What credit is and the different types of credit available
- How credit reports and credit scores work and the factors that go into building them
- Common options for building credit
And more!
Click through the slideshare to start your credit-education now.
StubbsGazette Anti Money Laundering E BookJames Treacy
A comprehensive guide to Anti Money Laundering/Countering the Financing of Terrorism in the Irish Credit Union Sector (also highly relevant to other regulated sectors)
Good day all,
Please find attached the June 2017 edition of our very informative Newsletter.
We look forward to your continuing support and comments. Please send all comments and suggestions to training@kawmanagement.com or training.kawmgmt@candw.ag.
Happy reading
Learn about how remittance challenges have grown as electronic payment usage has continued to grow. Learn about how the movement to electronic payments and remittances has created benefits for accounts payable but created a cash application challenge for those in accounts receivable. Created by Centreviews Business Intelligence Suite.
CPAs responsibilities to detect fraud in audits, required approaches, types of financial statement frauds and specific case examples of different types of financial statement fraud
Learn the basics of credit in this easy-to-follow, introductory course that includes:
- What credit is and the different types of credit available
- How credit reports and credit scores work and the factors that go into building them
- Common options for building credit
And more!
Click through the slideshare to start your credit-education now.
StubbsGazette Anti Money Laundering E BookJames Treacy
A comprehensive guide to Anti Money Laundering/Countering the Financing of Terrorism in the Irish Credit Union Sector (also highly relevant to other regulated sectors)
Protecting Your Organization Against Check and ACH FraudFraudBusters
Webinar series from FraudResourceNet LLC on Preventing and Detecting Fraud in a High Crime Climate. Recordings of these Webinars are available for purchase from our Website
This Webinar focused on the subject in the title
FraudResourceNet (FRN) is the only searchable portal of practical, expert fraud prevention, detection and audit information on the Web.
FRN combines the high quality, authoritative anti-fraud and audit content from the leading providers, AuditNet ® LLC and White-Collar Crime 101 LLC/FraudAware.
The two entities designed FRN as the “go-to”, easy-to-use source of “how-to” fraud prevention, detection, audit and investigation templates, guidelines, policies, training programs (recorded no CPE and live with CPE) and articles from leading subject matter experts.
FRN is a continuously expanding and improving resource, offering auditors, fraud examiners, controllers, investigators and accountants a content-rich source of cutting-edge anti-fraud tools and techniques they will want to refer to again and again.
White Paper: Key Compliance Challenges in Cross-Border PaymentsPayoneer
Businesses initiating cross-border payments are subject to multiple payment regulations in both the originating country and the country in which they land.
The costs of non-compliance can be severe, including failed payments, fines, reputational damage and in severe cases, imprisonment.
In this white paper you'll learn:
About cross-border regulations and why should you care
What local regulations and bodies you should know about
How to adopt a risk-based approach in order to be compliant
What to include in your Risk & Compliance Program checklist
Merchants are beginning to fight back, primarily through Chargeback Companies and lawsuits against the Cardholders, Issuing banks and even the Visa and MasterCard branded networks. One such lawsuit claims that “major credit card companies and the nation’s largest banks conspired to shift liability for fraudulent credit card transactions in the U.S. to merchants. The complaint claims that the move to cards that include electronic chips designed to be more secure—so-called EMV chips—has been plagued by technical glitches and used as cover to illegally shift fraud-protection costs.”
EMV in the U.S.: Putting It into Perspective for Merchants and Financial Inst...- Mark - Fullbright
All product and company names mentioned herein are for identification and educational purposes only and are the property of, and may be trademarks of, their respective owners.
There are many things that a company can do to reduce the cost of a data breach, if it happens. Including these activities in your approach to cybersecurity can be affective ways to further reduce cybersecurity risk.
Models for the cost of a data breach that are based upon historical industry data reveal a large "tail" distribution for the cost. For ten percent of companies that experience a large data breach, the costs can be quite high. Two important costs are investigation and notification. This presentation identifies actions that can be taken to lower the cost of investigation and notification.
Enforcement Focus on CCO Liability GER 2017Duff & Phelps
There is no doubt that wrongdoers should be held accountable for their crimes. Many years ago in The Wall Street Journal, Arthur Levitt Jr. said ‘hurt people where it hurts most, freedom or their pockets.’ As Mr. Clayton correctly stated, ‘[I]individual prosecution, particularly in the white-collar area, has a significant effect on behaviour.’
An in-depth discussion of the key trends driving card-not-present transactions and the subsequent increase in demand for smart transaction security solutions; includes a detailed review of the various transaction security technologies and solutions available for merchants and issuers
The dark side of enterprise silos may the fusion be with you v 2.0Freddie McMahon
This paper was originally produced as a contribution to the “Beyond Bureaucracy Challenge”, which was aimed at management innovators from around the world to share their most progressive practices and disruptive ideas around three goals:
● Making organizations more inspiring and engaging with everyone aligned by a deeply-felt sense of purpose to inspire and unleash imagination, initiative, and energy from every quarter.
● Developing an outside-in orientation that eliminates the gaps between “sense” and “respond”, to inject the voice of the customer and other relevant stakeholders into every decision, and to make the insights and observations of every individual—from edge to edge—matter.
● Managing without managers to reduce the performance drag of top-heavy management structures, replace “manager-management” with a more agile self- and peer-management, and replace rigid hierarchy with a vibrant social system.
Many of us have experienced the frustrations of working inside organisations: the lack of inspiration and engagement; the widening gap between sensing early and responding quickly; and the constraints of top-heavy management structures and administration. The impact of these frustrations has created unprecedented stress to individuals, whilst suppressing competitive and innovative growth, which creates even further stress to us all. The arch-enemy to the democratisation of the organisation is the enterprise silos that protect all those that do not want transparency or are simply too afraid to adapt. The pent up frustrations of so many people is ready to vent against the dark side of silos. Such an emotive outburst en masse when combined with the emerging shift towards the Social Enterprise, being advocated by leading cloud players, could lead to more change to the enterprise in the next five years compared to the past thirty years.
Protecting Your Organization Against Check and ACH FraudFraudBusters
Webinar series from FraudResourceNet LLC on Preventing and Detecting Fraud in a High Crime Climate. Recordings of these Webinars are available for purchase from our Website
This Webinar focused on the subject in the title
FraudResourceNet (FRN) is the only searchable portal of practical, expert fraud prevention, detection and audit information on the Web.
FRN combines the high quality, authoritative anti-fraud and audit content from the leading providers, AuditNet ® LLC and White-Collar Crime 101 LLC/FraudAware.
The two entities designed FRN as the “go-to”, easy-to-use source of “how-to” fraud prevention, detection, audit and investigation templates, guidelines, policies, training programs (recorded no CPE and live with CPE) and articles from leading subject matter experts.
FRN is a continuously expanding and improving resource, offering auditors, fraud examiners, controllers, investigators and accountants a content-rich source of cutting-edge anti-fraud tools and techniques they will want to refer to again and again.
White Paper: Key Compliance Challenges in Cross-Border PaymentsPayoneer
Businesses initiating cross-border payments are subject to multiple payment regulations in both the originating country and the country in which they land.
The costs of non-compliance can be severe, including failed payments, fines, reputational damage and in severe cases, imprisonment.
In this white paper you'll learn:
About cross-border regulations and why should you care
What local regulations and bodies you should know about
How to adopt a risk-based approach in order to be compliant
What to include in your Risk & Compliance Program checklist
Merchants are beginning to fight back, primarily through Chargeback Companies and lawsuits against the Cardholders, Issuing banks and even the Visa and MasterCard branded networks. One such lawsuit claims that “major credit card companies and the nation’s largest banks conspired to shift liability for fraudulent credit card transactions in the U.S. to merchants. The complaint claims that the move to cards that include electronic chips designed to be more secure—so-called EMV chips—has been plagued by technical glitches and used as cover to illegally shift fraud-protection costs.”
EMV in the U.S.: Putting It into Perspective for Merchants and Financial Inst...- Mark - Fullbright
All product and company names mentioned herein are for identification and educational purposes only and are the property of, and may be trademarks of, their respective owners.
There are many things that a company can do to reduce the cost of a data breach, if it happens. Including these activities in your approach to cybersecurity can be affective ways to further reduce cybersecurity risk.
Models for the cost of a data breach that are based upon historical industry data reveal a large "tail" distribution for the cost. For ten percent of companies that experience a large data breach, the costs can be quite high. Two important costs are investigation and notification. This presentation identifies actions that can be taken to lower the cost of investigation and notification.
Enforcement Focus on CCO Liability GER 2017Duff & Phelps
There is no doubt that wrongdoers should be held accountable for their crimes. Many years ago in The Wall Street Journal, Arthur Levitt Jr. said ‘hurt people where it hurts most, freedom or their pockets.’ As Mr. Clayton correctly stated, ‘[I]individual prosecution, particularly in the white-collar area, has a significant effect on behaviour.’
An in-depth discussion of the key trends driving card-not-present transactions and the subsequent increase in demand for smart transaction security solutions; includes a detailed review of the various transaction security technologies and solutions available for merchants and issuers
The dark side of enterprise silos may the fusion be with you v 2.0Freddie McMahon
This paper was originally produced as a contribution to the “Beyond Bureaucracy Challenge”, which was aimed at management innovators from around the world to share their most progressive practices and disruptive ideas around three goals:
● Making organizations more inspiring and engaging with everyone aligned by a deeply-felt sense of purpose to inspire and unleash imagination, initiative, and energy from every quarter.
● Developing an outside-in orientation that eliminates the gaps between “sense” and “respond”, to inject the voice of the customer and other relevant stakeholders into every decision, and to make the insights and observations of every individual—from edge to edge—matter.
● Managing without managers to reduce the performance drag of top-heavy management structures, replace “manager-management” with a more agile self- and peer-management, and replace rigid hierarchy with a vibrant social system.
Many of us have experienced the frustrations of working inside organisations: the lack of inspiration and engagement; the widening gap between sensing early and responding quickly; and the constraints of top-heavy management structures and administration. The impact of these frustrations has created unprecedented stress to individuals, whilst suppressing competitive and innovative growth, which creates even further stress to us all. The arch-enemy to the democratisation of the organisation is the enterprise silos that protect all those that do not want transparency or are simply too afraid to adapt. The pent up frustrations of so many people is ready to vent against the dark side of silos. Such an emotive outburst en masse when combined with the emerging shift towards the Social Enterprise, being advocated by leading cloud players, could lead to more change to the enterprise in the next five years compared to the past thirty years.
¿Qué es y qué hace un Consultor Ambiental?
Congreso Nacional del Medio Ambiente
Actividad Especial AE-33 CONAMA2016
Instituto Superior del Medio Ambiente (ISM)
StubbsGazette AML/CFT EBook for Credit UnionsStubbsGazette
A comprehensive guide to Anti Money Laundering/Countering the Financing of Terrorism in the Irish Credit Union Sector (also highly relevant to other regulated sectors)
PAGE 280APPLYING THE CONCEPTTRUTH OR CONSEQUENCES PONZI SCHEM.docxsmile790243
PAGE 280
APPLYING THE CONCEPT
TRUTH OR CONSEQUENCES: PONZI SCHEMES AND OTHER FRAUDS
In the financial world, you always have to be on the lookout for crooks. Fraud is the most extreme version of moral hazard, and it is remarkably common.
The term Ponzi scheme has its origins in a 1920 scam run by serial con artist Charles Ponzi. Promising a 50 percent profit within 45 days, he swindled unsuspecting investors out of something like $250 million in 2014 dollars. Ponzi never invested their money. Instead, he paid off early investors handsomely with the money he obtained from subsequent investors.
Financial laws are now far more elaborate than in Ponzi’s day, and governments spend much more to enforce them, but frauds persist.
Bernie Madoff is the leading recent example. For decades, Madoff was a respected member of the investment community and able to escape detection. In the same manner as Ponzi, Madoff was redeeming requests for funds with the money he collected from more recent investors. Madoff’s con, which may have begun as early as the 1970s, failed only when the financial crisis of 2007–2009 depleted his funds, making it impossible for him to pay off the final cohort of wealthy, sophisticated—yet apparently quite gullible—investors and financial firms. The Madoff scandal dwarfed Ponzi’s racket: at the time the scheme blew up, the losses were estimated at $17.5 billion, and extensive efforts at recovery have put final losses in the neighborhood of $7 billion.
Unfortunately, in a complex financial system, the possibilities for fraud are widespread. Most cases are smaller and more mundane than those of Madoff or Ponzi, but their cumulative size is significant. One source devoted to tracking just Ponzi-type frauds in the United States listed 70 schemes worth an estimated $2.2 billion in 2014 alone.*
We aren’t going to get rid of Ponzi schemes and other frauds (see In the Blog: Conflicts of Interest in Finance). But the mission of ferreting them out and prosecuting those responsible is essential. A well-functioning financial system is based on trust. That is, when we make a bank deposit or purchase a share of stock or a bond, we need to believe that the terms of the agreement are being accurately represented and will be carried out. Economies where property rights are weak and enforcement is unreliable also usually supply less credit to worthy endeavors. That means lower production, lower income, and lower welfare.
imagesIN THE BLOG
Conflicts of Interest in Finance
Financial corruption exposed in the years since the financial crisis is breathtaking in its scale, scope, and resistance to remedy. Traders colluded to rig the foreign exchange (FX) market, where daily transactions exceed $5 trillion, and to manipulate LIBOR, the world’s leading interest rate benchmark (see Chapter 13, Applying the Concept: Reforming LIBOR). Firms have facilitated tax evasion and money laundering. And Bernie Madoff engineered what was arguably the largest Ponzi.
The real cost of KYC & AML compliance for the financial sector - OndatoOndato
In this report, Ondato explores:
Compliance cost
Budget allocation
Non-compliance penalties
How KYC affects banks’ customers
A solution that cuts costs while maintaining compliance
Source: https://ondato.com/reports/the-real-cost-of-kyc-aml-compliance-for-the-financial-sector/
E-book: How to manage Anti-Money Laundering and Counter Financing of Terroris...Jitske de Bruijne
Financial Institutions continue to face heightened fines and regulatory scrutiny over their AML/CFT Programs. This e-book helps you to manage AML/CFT Programs.
Payment fraud is a persistent threat in today's digital world. Even some of these fraud events were found connected with the best credit card payment companies to top credit card payment processing. Visit us at: https://webpays.com/best-credit-card-payment-companies.html
Money Laundering in the Art, Collectibles, and Luxury Goods IndustryBrandonRuse1
Money laundering and fraud cases in the rare art and luxury goods industry are increasing as the gap between resources and budgets is being widened by COVID-19.
The 2017 Regulatory and Examination Priorities Letter1, published by FINRA on January 4th, is a fitting reminder of the resolve of Regulators to better execute their mission of investor protection and market integrity. Although the Libor and FX scandals might seem like distant memories, Regulators have continued on the war path. We would like to share some thoughts based on work we have been involved in last year. The idea is to help lawyers and banks have a grown-up discussion and be prepared if, or rather more likely, when, the Regulator knocks at the door.
The 2017 Regulatory and Examination Priorities Letter, published by FINRA on January 4th, is a fitting reminder of the resolve of Regulators to better execute their mission of investor protection and market integrity. Although the Libor and FX scandals might seem like distant memories, Regulators have continued on the war path. We would like to share some thoughts based on work we have been involved in last year in a regulatory competition investigation.
The 2017 Regulatory and Examination Priorities Letter1, published by FINRA on January 4th, is a fitting reminder of the resolve of Regulators to better execute their mission of investor protection and market integrity. Although the Libor and FX scandals might seem like distant memories, Regulators have continued on the war path. We would like to share some thoughts based on work we have been involved in last year. The idea is to help lawyers and banks have a grown-up discussion and be prepared if, or rather more likely, when, the Regulator knocks at the door.
Currently pi network is not tradable on binance or any other exchange because we are still in the enclosed mainnet.
Right now the only way to sell pi coins is by trading with a verified merchant.
What is a pi merchant?
A pi merchant is someone verified by pi network team and allowed to barter pi coins for goods and services.
Since pi network is not doing any pre-sale The only way exchanges like binance/huobi or crypto whales can get pi is by buying from miners. And a merchant stands in between the exchanges and the miners.
I will leave the telegram contact of my personal pi merchant. I and my friends has traded more than 6000pi coins successfully
Tele-gram
@Pi_vendor_247
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
The European Unemployment Puzzle: implications from population agingGRAPE
We study the link between the evolving age structure of the working population and unemployment. We build a large new Keynesian OLG model with a realistic age structure, labor market frictions, sticky prices, and aggregate shocks. Once calibrated to the European economy, we quantify the extent to which demographic changes over the last three decades have contributed to the decline of the unemployment rate. Our findings yield important implications for the future evolution of unemployment given the anticipated further aging of the working population in Europe. We also quantify the implications for optimal monetary policy: lowering inflation volatility becomes less costly in terms of GDP and unemployment volatility, which hints that optimal monetary policy may be more hawkish in an aging society. Finally, our results also propose a partial reversal of the European-US unemployment puzzle due to the fact that the share of young workers is expected to remain robust in the US.
how can I sell pi coins after successfully completing KYCDOT TECH
Pi coins is not launched yet in any exchange 💱 this means it's not swappable, the current pi displaying on coin market cap is the iou version of pi. And you can learn all about that on my previous post.
RIGHT NOW THE ONLY WAY you can sell pi coins is through verified pi merchants. A pi merchant is someone who buys pi coins and resell them to exchanges and crypto whales. Looking forward to hold massive quantities of pi coins before the mainnet launch.
This is because pi network is not doing any pre-sale or ico offerings, the only way to get my coins is from buying from miners. So a merchant facilitates the transactions between the miners and these exchanges holding pi.
I and my friends has sold more than 6000 pi coins successfully with this method. I will be happy to share the contact of my personal pi merchant. The one i trade with, if you have your own merchant you can trade with them. For those who are new.
Message: @Pi_vendor_247 on telegram.
I wouldn't advise you selling all percentage of the pi coins. Leave at least a before so its a win win during open mainnet. Have a nice day pioneers ♥️
#kyc #mainnet #picoins #pi #sellpi #piwallet
#pinetwork
Even tho Pi network is not listed on any exchange yet.
Buying/Selling or investing in pi network coins is highly possible through the help of vendors. You can buy from vendors[ buy directly from the pi network miners and resell it]. I will leave the telegram contact of my personal vendor.
@Pi_vendor_247
What price will pi network be listed on exchangesDOT TECH
The rate at which pi will be listed is practically unknown. But due to speculations surrounding it the predicted rate is tends to be from 30$ — 50$.
So if you are interested in selling your pi network coins at a high rate tho. Or you can't wait till the mainnet launch in 2026. You can easily trade your pi coins with a merchant.
A merchant is someone who buys pi coins from miners and resell them to Investors looking forward to hold massive quantities till mainnet launch.
I will leave the telegram contact of my personal pi vendor to trade with.
@Pi_vendor_247
what is the future of Pi Network currency.DOT TECH
The future of the Pi cryptocurrency is uncertain, and its success will depend on several factors. Pi is a relatively new cryptocurrency that aims to be user-friendly and accessible to a wide audience. Here are a few key considerations for its future:
Message: @Pi_vendor_247 on telegram if u want to sell PI COINS.
1. Mainnet Launch: As of my last knowledge update in January 2022, Pi was still in the testnet phase. Its success will depend on a successful transition to a mainnet, where actual transactions can take place.
2. User Adoption: Pi's success will be closely tied to user adoption. The more users who join the network and actively participate, the stronger the ecosystem can become.
3. Utility and Use Cases: For a cryptocurrency to thrive, it must offer utility and practical use cases. The Pi team has talked about various applications, including peer-to-peer transactions, smart contracts, and more. The development and implementation of these features will be essential.
4. Regulatory Environment: The regulatory environment for cryptocurrencies is evolving globally. How Pi navigates and complies with regulations in various jurisdictions will significantly impact its future.
5. Technology Development: The Pi network must continue to develop and improve its technology, security, and scalability to compete with established cryptocurrencies.
6. Community Engagement: The Pi community plays a critical role in its future. Engaged users can help build trust and grow the network.
7. Monetization and Sustainability: The Pi team's monetization strategy, such as fees, partnerships, or other revenue sources, will affect its long-term sustainability.
It's essential to approach Pi or any new cryptocurrency with caution and conduct due diligence. Cryptocurrency investments involve risks, and potential rewards can be uncertain. The success and future of Pi will depend on the collective efforts of its team, community, and the broader cryptocurrency market dynamics. It's advisable to stay updated on Pi's development and follow any updates from the official Pi Network website or announcements from the team.
Resume
• Real GDP growth slowed down due to problems with access to electricity caused by the destruction of manoeuvrable electricity generation by Russian drones and missiles.
• Exports and imports continued growing due to better logistics through the Ukrainian sea corridor and road. Polish farmers and drivers stopped blocking borders at the end of April.
• In April, both the Tax and Customs Services over-executed the revenue plan. Moreover, the NBU transferred twice the planned profit to the budget.
• The European side approved the Ukraine Plan, which the government adopted to determine indicators for the Ukraine Facility. That approval will allow Ukraine to receive a EUR 1.9 bn loan from the EU in May. At the same time, the EU provided Ukraine with a EUR 1.5 bn loan in April, as the government fulfilled five indicators under the Ukraine Plan.
• The USA has finally approved an aid package for Ukraine, which includes USD 7.8 bn of budget support; however, the conditions and timing of the assistance are still unknown.
• As in March, annual consumer inflation amounted to 3.2% yoy in April.
• At the April monetary policy meeting, the NBU again reduced the key policy rate from 14.5% to 13.5% per annum.
• Over the past four weeks, the hryvnia exchange rate has stabilized in the UAH 39-40 per USD range.
what is the best method to sell pi coins in 2024DOT TECH
The best way to sell your pi coins safely is trading with an exchange..but since pi is not launched in any exchange, and second option is through a VERIFIED pi merchant.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and pioneers and resell them to Investors looking forward to hold massive amounts before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade pi coins with.
@Pi_vendor_247
NO1 Uk Rohani Baba In Karachi Bangali Baba Karachi Online Amil Baba WorldWide...Amil baba
Contact with Dawood Bhai Just call on +92322-6382012 and we'll help you. We'll solve all your problems within 12 to 24 hours and with 101% guarantee and with astrology systematic. If you want to take any personal or professional advice then also you can call us on +92322-6382012 , ONLINE LOVE PROBLEM & Other all types of Daily Life Problem's.Then CALL or WHATSAPP us on +92322-6382012 and Get all these problems solutions here by Amil Baba DAWOOD BANGALI
#vashikaranspecialist #astrologer #palmistry #amliyaat #taweez #manpasandshadi #horoscope #spiritual #lovelife #lovespell #marriagespell#aamilbabainpakistan #amilbabainkarachi #powerfullblackmagicspell #kalajadumantarspecialist #realamilbaba #AmilbabainPakistan #astrologerincanada #astrologerindubai #lovespellsmaster #kalajaduspecialist #lovespellsthatwork #aamilbabainlahore#blackmagicformarriage #aamilbaba #kalajadu #kalailam #taweez #wazifaexpert #jadumantar #vashikaranspecialist #astrologer #palmistry #amliyaat #taweez #manpasandshadi #horoscope #spiritual #lovelife #lovespell #marriagespell#aamilbabainpakistan #amilbabainkarachi #powerfullblackmagicspell #kalajadumantarspecialist #realamilbaba #AmilbabainPakistan #astrologerincanada #astrologerindubai #lovespellsmaster #kalajaduspecialist #lovespellsthatwork #aamilbabainlahore #blackmagicforlove #blackmagicformarriage #aamilbaba #kalajadu #kalailam #taweez #wazifaexpert #jadumantar #vashikaranspecialist #astrologer #palmistry #amliyaat #taweez #manpasandshadi #horoscope #spiritual #lovelife #lovespell #marriagespell#aamilbabainpakistan #amilbabainkarachi #powerfullblackmagicspell #kalajadumantarspecialist #realamilbaba #AmilbabainPakistan #astrologerincanada #astrologerindubai #lovespellsmaster #kalajaduspecialist #lovespellsthatwork #aamilbabainlahore #Amilbabainuk #amilbabainspain #amilbabaindubai #Amilbabainnorway #amilbabainkrachi #amilbabainlahore #amilbabaingujranwalan #amilbabainislamabad
how can i use my minded pi coins I need some funds.DOT TECH
If you are interested in selling your pi coins, i have a verified pi merchant, who buys pi coins and resell them to exchanges looking forward to hold till mainnet launch.
Because the core team has announced that pi network will not be doing any pre-sale. The only way exchanges like huobi, bitmart and hotbit can get pi is by buying from miners.
Now a merchant stands in between these exchanges and the miners. As a link to make transactions smooth. Because right now in the enclosed mainnet you can't sell pi coins your self. You need the help of a merchant,
i will leave the telegram contact of my personal pi merchant below. 👇 I and my friends has traded more than 3000pi coins with him successfully.
@Pi_vendor_247
Introduction to Indian Financial System ()Avanish Goel
The financial system of a country is an important tool for economic development of the country, as it helps in creation of wealth by linking savings with investments.
It facilitates the flow of funds form the households (savers) to business firms (investors) to aid in wealth creation and development of both the parties
Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
Turin Startup Ecosystem 2024
Una ricerca de il Club degli Investitori, in collaborazione con ToTeM Torino Tech Map e con il supporto della ESCP Business School e di Growth Capital
how to sell pi coins in South Korea profitably.DOT TECH
Yes. You can sell your pi network coins in South Korea or any other country, by finding a verified pi merchant
What is a verified pi merchant?
Since pi network is not launched yet on any exchange, the only way you can sell pi coins is by selling to a verified pi merchant, and this is because pi network is not launched yet on any exchange and no pre-sale or ico offerings Is done on pi.
Since there is no pre-sale, the only way exchanges can get pi is by buying from miners. So a pi merchant facilitates these transactions by acting as a bridge for both transactions.
How can i find a pi vendor/merchant?
Well for those who haven't traded with a pi merchant or who don't already have one. I will leave the telegram id of my personal pi merchant who i trade pi with.
Tele gram: @Pi_vendor_247
#pi #sell #nigeria #pinetwork #picoins #sellpi #Nigerian #tradepi #pinetworkcoins #sellmypi
NO1 Uk Divorce problem uk all amil baba in karachi,lahore,pakistan talaq ka m...Amil Baba Dawood bangali
Contact with Dawood Bhai Just call on +92322-6382012 and we'll help you. We'll solve all your problems within 12 to 24 hours and with 101% guarantee and with astrology systematic. If you want to take any personal or professional advice then also you can call us on +92322-6382012 , ONLINE LOVE PROBLEM & Other all types of Daily Life Problem's.Then CALL or WHATSAPP us on +92322-6382012 and Get all these problems solutions here by Amil Baba DAWOOD BANGALI
#vashikaranspecialist #astrologer #palmistry #amliyaat #taweez #manpasandshadi #horoscope #spiritual #lovelife #lovespell #marriagespell#aamilbabainpakistan #amilbabainkarachi #powerfullblackmagicspell #kalajadumantarspecialist #realamilbaba #AmilbabainPakistan #astrologerincanada #astrologerindubai #lovespellsmaster #kalajaduspecialist #lovespellsthatwork #aamilbabainlahore#blackmagicformarriage #aamilbaba #kalajadu #kalailam #taweez #wazifaexpert #jadumantar #vashikaranspecialist #astrologer #palmistry #amliyaat #taweez #manpasandshadi #horoscope #spiritual #lovelife #lovespell #marriagespell#aamilbabainpakistan #amilbabainkarachi #powerfullblackmagicspell #kalajadumantarspecialist #realamilbaba #AmilbabainPakistan #astrologerincanada #astrologerindubai #lovespellsmaster #kalajaduspecialist #lovespellsthatwork #aamilbabainlahore #blackmagicforlove #blackmagicformarriage #aamilbaba #kalajadu #kalailam #taweez #wazifaexpert #jadumantar #vashikaranspecialist #astrologer #palmistry #amliyaat #taweez #manpasandshadi #horoscope #spiritual #lovelife #lovespell #marriagespell#aamilbabainpakistan #amilbabainkarachi #powerfullblackmagicspell #kalajadumantarspecialist #realamilbaba #AmilbabainPakistan #astrologerincanada #astrologerindubai #lovespellsmaster #kalajaduspecialist #lovespellsthatwork #aamilbabainlahore #Amilbabainuk #amilbabainspain #amilbabaindubai #Amilbabainnorway #amilbabainkrachi #amilbabainlahore #amilbabaingujranwalan #amilbabainislamabad
how to sell pi coins in all Africa Countries.DOT TECH
Yes. You can sell your pi network for other cryptocurrencies like Bitcoin, usdt , Ethereum and other currencies And this is done easily with the help from a pi merchant.
What is a pi merchant ?
Since pi is not launched yet in any exchange. The only way you can sell right now is through merchants.
A verified Pi merchant is someone who buys pi network coins from miners and resell them to investors looking forward to hold massive quantities of pi coins before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
2. Anomaly42.com2
Overview
Banks Race to Defend from further Reputational Damage
page 3
Reputational and Balance Sheet Damage
page 4
Systemic Failings in the First Line of Defence
page 6
Unknown Risks Worry Non-Executives
page 7
AML CFT: The Next Wave of Billion Dollar Fines
page 8
Siloed Organisations, Siloed Data Threatens Everything
page 10
Rethink Data, Rethink Client
page 11
Holistic Data, Smart Decisions
page 12
Living KYC EDD
page 14
The Economics of Enhanced Due Diligence
page 13
Conclusion
page 16
Benefits of Living KYC EDD
page 15
3. Anomaly42.com3
Banks Race to Defend from further
Reputational Damage
The next wave of billion dollar fines is underway
as authorities are coming to the banks, already
armed with evidence of KYCi
, AMLii
and CFTiii
systemic failings due to the way international
money transfers flow through correspondent
banks. This growing evidence shows how
money launderers’ businesses are successfully
laundering over a trillion dollars a year by
circumventing the controls of banks across the
world.
4. Anomaly42.com4
Eric H. Holder, Jr., [the Attorney General of the
United Statesiv
] , is leading the fight against deep
rooted corruption within the banks. We are now
at a watershed as $43bn of fines were given to
just 3 banks in an 18 month period:
Reputational and Balance Sheet
Damage
Eric H. Holder, Jr. Benjamin M. Lawsky
This means the best of class practices deployed
by leading banks is no longer good enough.
Holder is joined by Benjamin M. Lawsky [who is
the first Superintendent of the New York State
Department of Financial Services (NYSDFS),]
which as the regulator works closely with the US
Department of Justice (DoJ).
These two crusaders continue to send shock
waves through the world of financial services.
They are actively focused on using billion dollar
fines and criminal charges to remove ‘bad’
individual bankers from playing any further roles
within large financial institutions.
On the 19th May 2014, a guilty plea by Swiss
Bank Credit Suisse to a criminal chargev
for
its role in helping Americans evade taxes was
coupled with a $2.5 billion fine as part of an
agreement with U.S. Authorities. Separately, the
NYSDFS said it was determined not to revoke
the bank’s license in the state, but by making
this statement raises a further veiled threat. This
threat became reality a short time afterwards.
$13bn JP Morgan Chase (Nov 2013);
$11.6bn Bank of America (Jan 2013);
$9.5bn Bank of America (Mar 2014);
$8.9bn BNP Paribas (Jun 2014).
5. Anomaly42.com5
$8.97 billion fine
Suspension of dollar-clearing operations
through its New York branch and other
U.S. affiliates during all of 2015
Suspension of dollar-clearing as a
correspondent bank for unaffiliated third-
party banks in New York and London for
two years
The resignation/exit of 13 individuals,
including Group Chief Operating Officer
George Chodron de Courcel, from the
bank
The suspension of dollar-clearing
operations means the DoJ and NYSDFS
are to continue monitoring the bank’s
AML / CFTvii
and KYC EDDviii
controls that
need to be considerably strengthened to
avoid further costly delays or damaging
penalties.
This case covered the corporation and did
not include the subsequent investigation into
potential individual culpability. The BNP Paribas
suspension of dollar clearing may prove far more
damaging to the bank’s reputation and balance
sheet as it may struggle to retain business in
the area of international trade and wholesale
banking.
It would not be a surprise that, once systemic
control failings become more apparent in the
international banking sector, the collective
damage could reach £250bn by 2020ix
. Such
exposures could lead to material changes in the
marketplace including a change in the reliance
upon the dollar as a primary currency; the
framework for correspondent banking and a
fundamental rethink about KYC.
On the 30th June 2013, BNP Paribas pleaded
guilty to the concealment of more than $190
billion in transactions between 2002 and 2012
that included the dollar clearing on behalf of
the oil and gas finance business for santioned
countries from Geneva, Paris and Singapore,
the trade finance business from Milan, and for
oil and gas-related clients from Romevi
. This
resulted in:
6. Anomaly42.com6
Systemic Failings in the First Line
of Defence
Major banks involved with international
wire payments are highly dependent upon
automation to identify AML CFT anomalies.
This First Line of Defence (FLOD) is based on
automation, due to the volumes of money
transfer transactions and the time sensitive
nature of international payments.
FLOD automation generates anomalies that
need to be processed by bank administrators
as the Second Line of Defence (SLOD). Based
on our experience, 99.2% of these anomalies
are passed as acceptable by SLOD. These
acceptable transactions are regarded as ‘false
positives’ and have become ‘accepted’ as the
cost of compliance for doing business. But this
needs to be challenged for two reasons:
Unless algorithms are ‘continually’ calibrated to
align with the changing profile of major money
laundering players then the bank is likely to:
The high percentage of anomalies
generated as ‘false positives’ means
significantly higher compliance and
operational costs are incurred that do
little to materially protect the bank’s
reputation. In reality, a high percentage
of ‘false positives’ is a reflection of ‘weak’
decisioning algorithms within the FLOD
automation software.
Asoveratrilliondollarsisbeingsuccessfully
laundered every year, it is a reasonable
assertion that FLOD automation is
allowing money laudering transactions
through the process that ought to be
have been treated as suspicious activities.
These ‘false negatives’ are potentially the
most precarious types to be missed by the
bank’s controls. They are the transactions
that are most likely to inflict reputational
damage if they remain undetected until
found by investigators representing the
regulators and other external authorities.
‘False negatives’ means the bank is
exposed to ‘unknown’ risks, which can
become ‘known’ risks at any point over the
next ten years.
1
2
Miss identifying major money launderers
thus exposing the bank to future
reputational damage;
Incur the rising costs of compliance
and supervision to process exceptions
that really should have been treated as
acceptable STP business;
Face punitive action from the regulators in
fines etc.
7. Anomaly42.com7
Unknown Risks Worry Non-
Executives
From evidence we have examined, it is clear
that most international banks involved with
business-to-business international payments
in excess of one million transactions a year, are
highly likely to have missed identifying major
money launderers.
The reputational and balance sheet damage to
some of the largest banks in the world caused
by systemic AML CFT failings is a current and
serious Board-level issue.
Interestingly, we are finding non-executive
directors are demanding from their executives
to find better controls over ‘unknown’ risks as a
strategic imperative. Justifiably, pressure is also
coming from institutional and other types of
shareholders to create a more stable state for
growth.
The response of executives to these pressures
is to:
In our opinion, the answer is clearly no as they
are not designed to handle the sophistication
of the ‘top performing’ money launderers.
The reason is that major money launderers
have adopted complex ecosystems designed
to bypass the banks’ ‘best of class’ solutions.
These money laundering ecosystems are far
more sophisticated than the traditional money
laundering rings of yesteryear.
Non-executivesandotherBoard-Levelmembers
are now treating this situation with a greater
urgency as regulatory and judicial authorities
become far more challenging about money
being laundered and the financing of terrorism
because of the level of threat to socioeconomic
stability.
But are these materially large investments
enough?
Tighten up policies and procedures;
Materially increase the number of people
involved with governance, risk and
compliance;
Stop doing certain types of business;
Invest in better technology using ‘best of
class’ solutions.
8. Anomaly42.com8
AML CFT: The Next Wave of Billion
Dollar Fines
Our earlier White Paper AML CFT: “Money
Launderers Playing the Long Game” explains
how banks’ controls are systematically
bypassed.
There is growing realisation amongst leading
bankers upon how much of their business
intelligence can be extrapolated from wire
payment transactions that pass from bank to
bank. This level of transparency means the
DoJ and NYSDFS have access to wire payment
transaction data from over 50 banks that
are explicitly or implicitly involved in money
laundering.
This data is the start point for gathering KYC
EDD evidence involving suspicious activities
related to money laundering (including tax
crime) and the financing of terrorism. For every
money transfer where suspicious activity has
been identified, the authorities know the:
Why and how is this happening now?
The advances in Big Data are progressing very
rapidly, which can be illustrated in the following
table:
Wire payment currency and amount of
money.
Dates and times of the wire payment
instructions.
Name, address and country of the
originator firm.
Name, address and country of the bank
that has the originating firm as a client.
Name, address and country of the
originator bank’s correspondent bank.
Name and country of the beneficiary firm –
sometimes includes the address.
Name, address and country of the bank
that has the beneficiary firm as a client.
Name, address and country of the
beneficiary bank’s correspondence bank
and if appropriate their correspondent
bank.
Reason for the wire payment.
Any associated messaging.
BIG DATA 1.0
Collecting, connecting
and correlationg
structured and
unstructured data
BIG DATA 2.0
Artificial Intelligence
processing big data that
complements humans
BIG DATA 3.0
Artificial Intelligence
processing big data that
surpasses humans
BIG DATA 4.0
Artificial Intelligence
using IoTx
for sensing
early and responding
quickly
Past
Present
Future
9. Anomaly42.com9
By using Big Data 3.0xi
solution, advanced
automation can analyse data from SWIFTxii
and CHIPSxiii
to apply risk weightings, linked
with publically sourced data, to accurately find
high risk transactions. By taking these high
risk transactions and performing a “Know Your
Customer (KYC) Enhanced Due Diligence (EDD)”
examination using primarily publicly sourced
data, authorities are able to unveil suspicious
complex corporate structures across multiple
accounts involving multiple jurisdictions,
without any further consultation with the banks
involved.
This new generation of automation is able to
very rapidly find high risk transactions that
were previously missed by FLOD and SLOD.
To try to find such high risk transactions using
AML CFT analysts using contempory technology
and processes it could take 12 months or
more, or it could completely fail to find serious
money laundering ecosystems that are
bypassing the bank’s controls.
The DoJ and NYSDFS are able to identify every
bank that has been explicitly or implicitly
involved with suspicious AML CFT transactions
from studying the life cycle data of each
wire payment from the originator firm to the
beneficiary firm. In other words, when the
DoJ and NYSDFS investigate one bank, the
evidence gathered includes the other banks
involved. The DoJ and NYSDFS stopping BNP
Paribas undertaking dollar-clearing as a
correspondent bank for unaffiliated third-party
banks in New York and London for two years
is a strong signal to other banks involved with
international wire payments.
The type of evidence that can now be obtained
starting from a wire payment transaction and
applying Living KYC EDD using public sourced
data is shocking bankers to the core. This goes
way beyond the type of data banks use from
the traditional providers of information. The
implications are profound as KYC EDD + AML
CFT coupled with international wire payments
signals the next wave of billion dollar fines.
10. Anomaly42.com10
Such siloism is failing to handle increasing rates
of complexity and arguably is the single biggest
cause to the spiralling costs of regulation,
compliance and supervision, whilst constraining
competitive and innovative growth for the
benefits of clients and shareholders alike.
As the rate of complexity, velocity and volatility
increases, siloism cultivates more and more
fragmentation of data and fragmented ways of
working. This is a fertile ground for cultivating
unknown risks that eventually surface to drive
problems and in some cases creates a serious
crisis.
Money Laundering is now a clear and present
danger to banks, especially those involved with
international wire payments.
Siloed Organisations, Siloed Data
Threatens Everything
KYC is core to the values of global banking
business. However, banks are increasingly
hindered from really knowing their customer
by the way they are organised around silos
covering processes, people and data. In reality,
customer data is highly fragmented with at
least 80% of this data being in an unstructured
format (i.e. paper, fact finds, contracts, service
level agreements, correspondence, emails,
instant messaging, phone calls, identity
documents, checklists, spreadsheets, invoices,
complaints, enquiries etc.).
In the case of SDD (simplified due diligence),
CDD (customer due diligence) or when deemed
necessary EDD (enhanced due diligence) there
is a need to collect external sources of data,
which is mostly in an unstructured format.
Siloism by its very nature is a collection of
walled gardens within the same organisation
that engenders protectionism and self-interest
type behaviours, particularly in times of stress.
11. Anomaly42.com11
Rethink Data, Rethink Client
Most wealthy individuals often own firms,
are directors of firms, and are shareholders
of firms. As advocated by the FATFxiv
and the
EC 4MLDxv
it is important to understand the
firms involved with wire payment transactions,
including the true ownership by individuals
even though this may involve complex
structural layering. The natural synergy
between wealthy individuals and corporate
banking, combined with the complexities
of governance, risk and compliance has led
to the trend to converge these two banking
businesses.
Banks have always focused on winning,
retaining and deepening customer
relationships, but nowadays this is far more
complex to undertake for many reasons,
including the ease of creating companies,
establishing bank accounts in different
countries and doing business across many
jurisdictions. Increasingly, executives are
finding that the winning differentiator is no
longer the product or the price, but the level of
engagement in creating an intimate long-term
relationship with the customer. The competitive
differentiation is the way engagement is a
more strategic way of looking at customer
relationships and personalised services.
Taking a holistic view of all customer data, both
structured and unstructured data, from inside
and outside the bank, provides the means for a
strategic engagement to be undertaken.
AML CFT creates further challenges as it also
needs to take into consideration wire payment
transactions, other banks clients and all
correspondent banks involved.
12. Anomaly42.com12
Holistic Data, Smart Decisions
Using this approach, holistic data refers to the creation of a deeper, more meaningful collection
and connection of data about firms and the individuals involved. This requires joined-up data
across the different functional silos of the bank.
The following diagram is a simplistic representation to a strategic reposition to Living KYC
involving internal and external data, including publically sourced and wire payments that involve
inter-bank transactions especially those covering business from a firm / individual to a firm /
individual.
This diagram shifts EDD from a fringe activity to the modus operandi. This requires treating
Enhanced Due Diligence not as a regulatory overhead, but a way to develop new ways to ensure
that customers are engaged in all of their interactions with the bank and that such richness of
data enables the bank to be more proactive in anticipating customer needs and expectations,
and fulfilling them more effectively and efficiently. This shift is fundamental for smarter decisions
that results in treating customers fairly and driving new levels of automation for AML CFT and
other relevant regulator demands.
EDD
InternalData
KYC: Know Your Customer
EDD: Enhanced Due Diligence
TCF: Treat Customers Fairly
AML: Anti Money Laundering
CFT: Combating the Financing of Terrorism
Data
Data Data
Wire Payment
Data
ExternalData
Living
KYC
TCF
AML
CFT
13. Anomaly42.com13
The Economics of Enhanced Due
Diligence
Traditionally, banks perform SDD or CDD. The
latter is time consuming and for some banks
it can take many weeks or even months to
perform client on-boarding. EDD (Enhanced
Due Diligence) is regarded as an exception as
it involves higher costs and longer time periods
to perform.
EDD automation changes the economics of KYC
as it collects external data from a diverse set of
sources than can be used to prefill structured
data formats. The ability to use automation to
extrapolate data from unstructured formats
at costs lower than SDD or CDD, is a game
changer. There is still the manual process of
identity verification by providing documents
such as a passport, but even in this situation
there are new forms of self-service using smart
phones.
Advanced EDD automation that fundamentally
lowers the costs by doing more for less means
EDD becomes the modus operandi and
replaces the need for SDD and CDD. Inevitably,
this will become the golden standard for
KYC with AML CFT being a beneficiary of this
change.
This new approach we call Living KYC EDD
that drives market and revenue growth, whilst
lowering costs and risks.
14. Anomaly42.com14
Living KYC EDD
Living KYC EDD is about having up-to-date data about the customer. As ownership of firms are
continually changing there is a need to move beyond the constraints of customer on-boarding
and periodic reviews. The provisioning of daily updates from external data sources provides the
means for the bank to be aligned with change being treated as the norm.
The following diagram shows a simplistic graphical data visualisation in context to a single wire
payment. Naturally, reality is more complex than this illustration but it is enough to show that all
the structured and unstructured client data nodes (circles) have relationships (lines) and both
have properties (text).
15. Anomaly42.com15
Today, advanced technology enables Living KYC EDD to become a reality and the ability to
reconstruct structured and unstructured data into dynamic visualisation formats and develop
new forms of automation to detect positive and negative anomalies.
Benefits of Living KYC EDD
By taking a holistic and dynamic view of Living KYC, there is a fundamental shift that takes the
capabilities of the bank to a new level. The benefits of Living KYC are profound:
Protects the brand and balance sheet
from reputational damage and reduces
the provisions needed for ‘conduct risk’.
Protects senior bankers from criminal
litigation and losing their licence re: Senior
Persons Regime
Provides better assurance to board
members and shareholders alike of
putting controls in place designed to
tackle better ‘unknown risks’.
Uses automation in a step change to
reverse the continual costs of governance,
compliance and risk control.
1
2
3
4
5
6
7
Provides a new capability of getting to
know customers better, meeting emerging
customer demands and anticipating future
customer needs.
Enables better customer engagement and
more personalised products and services.
Develops the next generation of middle
office automation by bringing unstructured
and structured data together in redefined
formats to carry out work that before
needed subject matter experts to process
the work.
16. Anomaly42.com16
Conclusion
The worrying exposures banks now have, in terms of the authorities using advanced technologies
to find negative anomalies in wire payments data, means proactive and pre-emptive action is
needed. This emergent threat again raises serious questions about the role of the ‘Big Four’
auditors and their ability to detect systemic control weaknesses. Both the banks and auditors
are also exposed to Sarbanes Oxley legislation for ensuring proper policy and procedures are in
place.
A different type of strategic solution is needed rather than throwing armies of people at
the problem. By wisely taking a different perspective it means there is now the capability to
repurpose defensive costs to become a strategic investment that reduces the exposure of brand
contamination, whist laying the foundation for market and revenue growth. Such new capability
enables banks to sense early for informed timely decisions in quick response to ever changing
circumstances for refining and expanding the value proposition to its customers.
NYSDFS announces PricewaterhouseCoopers regulatory advisory services will face a 24-month
consulting suspension, pay a $25 million fine; and will have to implement reforms after
misconduct during work at bank of Tokyo Mitsubishi.xvi
17. Anomaly42.com17
References
i
KYC = Know Your Customer
ii
AML = Anti-Money Laundering
iii
CFT = Combating the financing of terrorism
iv
Eric H. Holder, Jr. was sworn in as the 82nd Attorney General
of the United States on February 3, 2009 by Vice President Joe
Biden. http://www.justice.gov/ag/
v
Credit Suisse pleads guilty to U.S. criminal charge in tax probe
http://www.reuters.com/article/2014/05/19/us-creditsuisse-
investigation-idUSBREA4I0E620140519
vi
France’s BNP to pay $9 billion in U.S. sanctions case, face
dollar-clearing ban http://www.reuters.com/article/2014/06/30/
us-bnp-paribas-settlement-idUSKBN0F52HA20140630
vii
AML anti money laundering; CFT combating the financing of
terrorism
viii
KYC know your customer; EDD enhanced due diligence
ix
The $250bn estimate for damages is based on taking the
market cap for the top 21 banks as at 31st March 2014 (source:
http://www.relbanks.com/worlds-top-banks/market-cap). At this
time the total market cap for the 21 banks was valued at US$
2,712 bn. By using a formula of using the BNP Paribas $8.9bn
fine as a percentage of their market cap, we have calculated the
equivalent across the 21 banks. This puts a value of the potential
damage to be around US$ 251.40bn. A further consideration is
the damage to the banks’ balance sheets, including provisioning
for conduct risk; the impact upon the brand contamination
to shareholders; the loss of trust by clients and other banks
to revenue generation; and the possible suspension of dollar
clearing including as a correspondent bank.
x
IOT Internet of Things
xi
Big Data 1.0 Searching Connected Data; Big Data 2.0 Artificial
Intelligence Complementing Humans; Big Data 3.0 Artificial
Intelligence Surpassing Humans
xii
SWIFT Society for Worldwide Interbank Financial
Telecommunication http://www.swift.com/
xiii
CHIPS is the largest private-sector U.S.-dollar funds-transfer
system in the world. https://www.chips.org
xiv
FATF Financial ActionTak Force http://www.fatf-gafi.org/ is
the leading authority for combating money laundering and the
financing of terrorism, which is backed by the department of
treasury from leading countries.
xv
EC 4MLD The European Commission (the “Commission”)
Fourth Money Laundering Directive (“4MLD”)
xvi
http://www.dfs.ny.gov/about/press2014/pr1408181.htm