Author: The PayLynxs Team

Fraud monitoring and Anti-Money Laundering (AML) monitoring are both critical components of financial crime prevention, but they focus on different aspects of criminal activity within financial institutions. Here’s a comparison of the two:

FRAUD MONITORING

• Primary Focus: To detect and prevent fraudulent activities such as identity theft, account takeovers, credit card fraud, check fraud, and other forms of financial deception.
• Goal: To protect customers and the institution from financial losses and reputational damage caused by fraudulent actions.

Scope

• Transactions: Monitors transactions for signs of fraud, such as unusual spending patterns, large withdrawals, or multiple failed login attempts.
• Behavioral Analysis: Uses behavioral analytics to identify anomalies in customer behavior that may indicate fraud.
• Authentication: Implements robust authentication mechanisms to prevent unauthorized access to accounts.

Techniques

• Rule-Based Systems: Uses predefined rules and thresholds to flag suspicious activities.
• Machine Learning: Employs machine learning algorithms to detect complex and evolving fraud patterns.
• Real-Time Alerts: Provides real-time alerts to flag potentially fraudulent transactions for immediate review.

Examples

1. Detecting an unusually high number of transactions from a single account in a short period.
2. Identifying transactions from locations inconsistent with the customer’s typical behavior.
3. Spotting changes in account details, such as address or contact information, that may indicate account takeover.

AML MONITORING

Primary Focus: To detect and prevent money laundering activities, which involve disguising the origins of illegally obtained money to make it appear legitimate.

Goal: To comply with regulatory requirements, protect the financial system’s integrity, and prevent the facilitation of criminal activities.

Scope

• Customer Due Diligence: Involves Know Your Customer (KYC) processes to verify customer identities and assess their risk.
• Transaction Monitoring: Monitors transactions for patterns consistent with money laundering, such as structuring, layering, and integration.
• Suspicious Activity Reporting: Identifies and reports suspicious activities to regulatory authorities.

Techniques

• Risk-Based Approach: Implements a risk-based approach to AML, where higher-risk customers and transactions receive more scrutiny.
• Transaction Analysis: Analyzes transaction data for red flags, such as large cash deposits, rapid movement of funds, or transactions with high-risk countries.
• Enhanced Due Diligence: Applies enhanced due diligence for high-risk customers, including politically exposed persons (PEPs) and those from high-risk jurisdictions.

Examples

1. Identifying a series of small deposits that just below reporting thresholds (structuring).
2. Spotting complex and rapid transfers between accounts that lack a clear business purpose (layering).
3. Detecting transactions involving countries with weak AML regulations or high levels of corruption.

KEY DIFFERENCES

Fraud Monitoring

• Focuses on preventing financial losses due to fraudulent activities targeting customers or the institution.
• Often uses real-time detection and response to stop fraud before it affects customers.
• Primarily driven by the need to protect customers and the institution, with some regulatory oversight.
• Covers a wide range of fraudulent activities, including theft, deception, and unauthorized transactions.

AML Monitoring

• Focuses on preventing the use of the financial system for laundering illicit funds and complying with regulatory requirements.
• Involves more comprehensive data analysis and reporting to identify suspicious patterns and comply with legal obligations.
• Strictly governed by regulatory frameworks and requires regular reporting to authorities.
• Specifically targets activities related to money laundering, such as structuring, layering, and integration of illicit funds.

Both fraud and AML monitoring are essential for maintaining the integrity and security of financial institutions, but they require different tools, techniques, and expertise to be effective.

The ever-evolving landscape of Anti-Money Laundering (AML) regulations took a significant turn with the enactment of the Anti-Money Laundering Act of 2020 (AMLA). Among its various provisions, AMLA mandates the Financial Crimes Enforcement Network (FinCEN) to conduct a comprehensive review of the Suspicious Activity Reports (SARs) process. This review aims to streamline the SAR filing system, evaluate existing thresholds, and explore the feasibility of further automation. In this blog post, we delve into the potential implications of this provision and what FinCEN might recommend for SAR filing.

The AMLA Mandate: An Overview

The SAR filing process has long been a crucial aspect of the AML framework, serving as a means for financial institutions to report suspicious transactions that may indicate money laundering or other illicit activities. AMLA’s mandate for FinCEN to review and potentially enhance this process reflects a recognition of the need for modernization and efficiency in combating financial crimes.

The Implications of AMLA Changes

While the specific recommendations from FinCEN regarding SAR filing are yet to be unveiled, the implications of this provision are significant. The review opens the door to potential changes in the following areas:

1. Thresholds and Criteria: FinCEN may reconsider existing SAR filing thresholds and criteria, adjusting them to better align with the evolving nature of financial crimes. This could involve reevaluating the dollar amount or transaction characteristics that trigger a SAR filing.
2. Automation Possibilities: A key aspect of the review involves exploring opportunities for further automation of the SAR filing process. Automation can enhance the efficiency of identifying and reporting suspicious activities while reducing the burden on financial institutions.
3. Enhanced Collaboration: The SAR filing review may encourage greater collaboration between financial institutions and regulatory bodies. This could involve the sharing of best practices, insights, and intelligence to strengthen the overall AML framework.

The Current Landscape: No Public Pronouncements

As of now, there has been no public movement or pronouncements from FinCEN regarding the SAR filing review mandated by AMLA. The lack of updates adds an element of uncertainty for financial institutions, making it challenging to anticipate the specific changes that may be recommended.

Anticipating FinCEN’s Recommendations

While we await official guidance from FinCEN, it’s essential for financial institutions to stay proactive and prepared. Potential recommendations could focus on leveraging technology for more efficient SAR filing, refining criteria for reporting, and fostering a collaborative environment to combat financial crimes effectively.

Conclusion: Navigating the Future of SAR Filing

As FinCEN undertakes the mandated review of the SAR filing process, financial institutions find themselves at a critical juncture. The potential recommendations could reshape how suspicious activities are identified, reported, and managed. Staying informed, maintaining flexibility in compliance processes, and considering technological solutions will be key to navigating the evolving landscape of SAR filing requirements.

In the midst of these changes, financial institutions can benefit from solutions that offer adaptability and efficiency in compliance. If you are interested in learning more about the PayLynxs advanced SAR workflow, book a complimentary demo here.

In the ever-evolving landscape of financial crimes, the cost of illicit activities has surged to unprecedented levels, prompting a crucial reevaluation of Anti-Money Laundering (AML) regulations. The Anti-Money Laundering Act of 2020 (AMLA) stands out as a pivotal response, signaling a significant shift towards a risk-based approach to AML monitoring. In this blog post, we’ll explore what risk-based AML monitoring entails and why it’s becoming increasingly essential in the fight against financial crimes.

Understanding the Need for Change

The traditional check-the-box AML compliance approach has proven insufficient in the face of sophisticated and rapidly evolving financial crimes. The surge in financial crime costs, reaching $274.1 billion in 2022, underscores the urgency for a more effective and risk-focused strategy.

Embracing a Risk-Based Approach to AML Monitoring

Risk-based AML monitoring represents a paradigm shift from a one-size-fits-all compliance model to a more nuanced and targeted strategy. Rather than applying uniform measures to all transactions, this approach involves identifying and prioritizing risks based on factors such as customer profiles, transaction patterns, and geographic locations.

Key Components of Risk-Based AML Monitoring

1. Customer Risk Assessment: Evaluate the risk associated with each customer by considering factors like their business type, location, and transaction history.
2. Transaction Monitoring: Implement advanced analytics to detect unusual patterns or deviations from established norms in transactional behavior.
3. Enhanced Due Diligence (EDD): Apply additional scrutiny to high-risk customers, ensuring a more thorough understanding of their activities and associated risks.
4. Real-Time Alerts: Leverage technology to generate real-time alerts for potentially suspicious activities, enabling swift and proactive responses.
5. Continuous Monitoring: Establish ongoing surveillance mechanisms to adapt to evolving risks and ensure compliance remains effective over time.

The Challenge: Lack of Guidance

While the intent of AMLA is clear, the lack of implementation guidance from FinCEN has left financial institutions in a challenging position. The absence of clear directives creates uncertainty and impedes the seamless transition to a risk-based AML monitoring framework.

SimpliRisk by PayLynxs

In response to the need for a comprehensive and user-friendly solution, PayLynxs developed SimpliRisk—a cost-effective BSA/AML compliance platform designed to simplify the complexities of risk-based AML monitoring. With customizable, intelligent rules, SimpliRisk allows financial institutions to initiate the transition immediately and tailor it uniquely to their business needs.

As the financial industry adapts to the demands of AMLA and strives for more effective compliance, the role of risk-based AML monitoring becomes increasingly pivotal. With SimpliRisk, PayLynxs offers a solution that not only aligns with the evolving regulatory landscape but also provides a user-friendly and cost-effective platform to fortify your institution against financial crimes. Take the leap into the future of compliance with SimpliRisk today by booking a complimentary demo.

Criminals ramp up their efforts to take advantage of individuals and their financial institutions during the holidays.  By knowing what to look for, you can use SimpliRisk to help you detect these scams.  In this blog post, we will explore some of the common holiday scams and provide suggestions for how to use SimpliRisk to aid you in detecting them.

Common Holiday Scams

• Phishing Attacks – Scammers send fraudulent emails or messages designed to trick recipients into revealing personal information, login credentials, and to send money from their account.
• Account Takeover Fraud – Criminals often attempt to take control of customers’ bank accounts during the holiday season after successful Phishing attacks.
• Elder Abuse – Romance Scams and Tech Support Scams target elderly individuals to perform transactions or provide accounts access directly or from screen share / screen control sessions.

SimpliRisk Guidance

Many of these scams result in Authorized Push Payment (APP) scenarios, which is very hard to prevent, but can be detected with some of the following configurations within SimpliRisk.

• Out of Pattern transactions can detect APP scenarios. Using SimpliRisk monitoring series 900 or 5400 you can detect this type of behavior.
• Elder abuse monitoring will look at multiple types of transactions to identify unusual behavior, given historical trends. Using SimpliRisk monitoring series 5200 you can detect this type of behavior.
• If there are particular names of entities, processors, or people that you see during the holidays associated with fraud, then use SimpliRisk monitoring series 6600 to help you detect any other transactions with this same information.

Conclusion

Banks and credit unions are at the front lines in the battle against holiday scams, as they often bear the responsibility of safeguarding their customers’ financial well-being. By staying vigilant and proactive, banks can significantly reduce the risk of financial losses and ensure their customers have a safe and secure holiday season. Education, advanced security measures, and effective communication with customers are key in this endeavor. Together, banks and their customers can enjoy the holiday season with peace of mind.

If you would like a consultative session to review the guidance provided in this blog, please reach out to schedule a session with our support team.