Compliance

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If You Knew Google Like We Know Google or why Google is not (Google), Goog!, Goo* AND/OR a ~Google

In the world of KYC, Google has become a ubiquitous component of client onboarding, CDD, EDD and Vendor Due Diligence best practices. Searches are often written once and then enshrined in procedures. As a supplement to checks against traditional sanctions, public record, PEP, criminal record, litigation and specialized adverse media providers, a Google search can reveal valuable, risk relevant […]

By |May 13th, 2015|Alacra, Compliance, Internet and Technology, Posts|

Inside the LEI — Issue IV — Part 2

This is Part 2 of excerpted posts from Alacra’s Inside the LEI series – Issue IV

 

Percentage of Rated Entities Assigned an LEI

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The rated universe Alacra covers includes those entities/issuers rated by A.M. Best, Moody’s, S&P and Fitch. This totals […]

OCC Clarifies Its Expectations in Updated Guidance for Handling Third-Party Relationships – An Alacra Compliance Primer

In October 2013, the Office of the Comptroller of the Currency (OCC), the U.S. regulator of national banks, issued Bulletin 2013-29–guidance for assessing and managing risks associated with third-party relationships. The OCC defines a third-party relationship as “any business arrangement between a bank and another entity, by contract or otherwise.”[1] This bulletin […]

Alacra Compliance Primer – Enforcement Actions for U.S. Sanctions Violations Offer Lessons for Compliance

Barbara Keller, CAMS, CFCS, and former Deputy Associate Director for Compliance and Enforcement for FinCEN, has written a new Alacra Compliance Primer which details the evolution of several of the most significant cases of U.S. sanctions violation cases, some of which also included penalties for AML violations. Recent actions have been taken primarily against foreign […]

Eggs, Bacon and Regulation

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Chris Skinner, Chairman, Financial Services Club

On Tuesday in London, Alacra and our content partner CounterpartyLink hosted a breakfast meeting called Eggs, Bacon and Regulation.  Chris Skinner, chairman of the Financial […]

LEI: Stronger Foundation Needed

It might seem crazy to argue with SIFMA president and CEO Kenneth Bentsen Jr. writing to Treasury Secretary and FSOC Chair Jacob Lew advocating a wider regulatory mandate for Legal Entity Identifiers, but here goes.

Of course a wider regulatory mandate will increase and accelerate adoption.  If regulators worldwide grabbed their sticks and lightning bolts […]

Alacra Compliance Primer – Positive Developments on Beneficial Ownership

It is widely accepted that illicit actors continue to create legal entities, masking beneficial ownership information in order to facilitate access to the financial system and conduct financial crimes. A number of developments have recently occurred that may help the United States make progress on requiring the identification of beneficial ownership of businesses and accountholders… […]

Positive Developments on Beneficial Ownership

It is widely accepted that illicit actors continue to create legal entities, masking beneficial ownership information in order to facilitate access to the financial system and conduct financial crimes. A number of developments have recently occurred that may help the United States make progress on requiring the identification of beneficial ownership of businesses […]

How Technology Can Help On-Boarders Acquire and Understand Beneficial Ownership Information

In September we posted Upcoming Changes to KYC Beneficial Ownership Regulatory Requirements – A Primer, which outlined how different regulatory regimes were going to require more and more accurate beneficial ownership information.  This post spurred several conversations with KYC practitioners, many of whom asked how technology might help with the beneficial ownership burden.  Last […]

The Missing Mandates

The LEI Regulatory Oversight Committee (http://www.leiroc.org/) has, as of November 18, more than 50 members representing over 30 countries.  Most of the committee members represent the central bank or another regulatory body in their respective jurisdictions.  What continues to surprise and confuse market participants, though, is that to date only two regulatory bodies […]