The U.S. Government is extremely concerned about how terrorists, drug cartels, criminal enterprises and even rogue governments launder money to hide their criminal enterprises.
There are good reasons why such groups might want to transfer ill-begotten cash through banks and financial organizations. For example, during the height of his cocaine empire, famed drug dealer Pablo Escobar was said to be making $450 million dollars a week.
Not able to put most of his cash in banks, he stocked it in warehouses and buried cash underground. According to historians around $2.1 billion dollars, or around 10 percent of his total was written off each year because it was eaten by rats or destroyed through water damage.
While anti-money laundering laws have been in effect in the U.S (as well as most civilized countries) for many years. One effective way that anti-money laundering efforts took place in the U.S. is via confiscation.
Back in the mid-80s, the Federal government changed anti-confiscation laws.
As a consequence, even if a police officer in any U.S. police jurisdiction doesn’t have the evidence to arrest you for committing a crime, if he suspect any cash you have in the trunk of your car or under the bed of your house was illegally obtained, they can confiscate that money and it is up to you prove the money was obtained legally to get it back.
However, while anti-money laundering in the U.S. concentrated on stopping drugs, after the 9/11 terrorist attacks which killed over 3,000 people and destroyed many buildings, including the World Trade Towers, it was discovered that bank wire transfers were used to finance the terrorists here in the U.S.
After 9/11 the Patriot Act forced all banks and financial organizations, security-broker dealers, and mutual fund companies to comply with Anti-Money Laundering compliance procedures.

What’s currently required under the BSA/AML procedures?
There are 5 major components to Pay Lynxs BSA/AML procedures:
- Risk Assessment
- Internal Controls Review
- Third-party Audit Testing
- Designating an BSA/AML Compliance Officer
- Conducting BSA/AML Compliance Training
Concerning the first, Risk Assessment, this should go far beyond the obvious such as the risk inherent with their products and services and customers. It’s a good idea that any institution consults with local and Federal law enforcement.
For example, the National Drug Threat Assessment via the National Drug Intelligence Center reports 8 major drug running corridors in the United States. Banks and other financial institutions with any of these 8 drug corridors have to be particularly careful.
Concerning Internal Controls, all policies, procedures, and processes should be reviewed to maintain strict compliance with the law using OFAC Watchlist scanning system. In particular, policies should be in place to generate any reports required by the law, when such reports are required and who in the institution will create them.
Of particular concern and vital for the success of the program is the requirement that one expert on BSA/AML policies be assigned as the compliance officer. The compliance offer must have all the resources necessary to ensure the institution meets every intent of the law.
To ensure the law is fully complied with, both in spirt and in practice, third-party testing and audits are required.
Although AMS Audits involve a full review of the companies AML compliance manual as well as a review of Customer Identification procedures and a look at the company’s compliance training program, the most important element is testing.
For example, a third-party operative may try to deposit $15,000 cash for a product or service and then the money is followed through the institution. Was the cash transaction reported to the Federal Government as required.
Another operative may act as a test case, working for a conduit for a drug cartel, and just how much customer identification information is required will be tested.
Finally, the company must have a rigorous compliance training program so that the full intent of the law is implemented.





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