What is money laundering, anyway? How does it work? This series discusses how the proceeds of criminal activity could find its way to your advisory firm, and what to do about the possibility. We get into these topics:

• The Bank Secrecy Act -- This law is the statutory basis for anti-money laundering obligations and a number of reports that might have to be filed. These reports include:

  • CTRs – Currency Transaction Reports

  • CMIRs – Reports of International Transportation of Currency or Monetary Instruments

  • FBARs – Reports of Foreign Bank and Financial Accounts

• SARs – Suspicious Activity Reports

  • What can trigger them?

  • When should you NOT file one?

• The Office of Foreign Assets Control, or OFAC, administers sanctions programs that limit some specified transactions. To do that it uses, among other things:

  • List of Specially Designated Nationals

    • Terrorists and foreign organizations

    • Drug traffickers

    • Proliferators of WMDs

  • Country sanctions programs that address rogue states such as North Korea and Iran.

• AML Compliance Programs will help keep your firm out of trouble. Here we discuss:

  • Filing appropriate reports

  • Implementing measures to identify new clients and detect suspicious activity

  • Looking for red flags

• OFAC Compliance overlaps somewhat with AML compliance generally, but we also discuss specific ways to stay on the right side off that office, including:

  • Structural protections

  • Employee training

  • Screening clients

  • Checking transactions