This will expedite the AML process by ensuring the SAR is quickly routed to the same regulator. Opinion Writing Check-in: Homework Your second graders have been developing their opinion writing over the course of the year. In the event you determine to allege another crime, such as drug trafficking, ask yourself how you have made and can later justify such a determination. Then they'll do an easy writing exercise. Article With ‘FinCEN Files,’ don’t shoot the messenger. Mar 27, 2016 - This unit has been completely updated as of April 26, 2018. This site uses cookies. I will save that for another day—for now, I want to focus upon the SARs, because in our world of AML compliance, this is where the rubber hits the road. Martin Woods is a former detective turned compliance officer who has experience with major compliance cases and settlements from a number of perspectives. We are developing an agenda focused on cutting-edge international topics, as well as new perspectives on the fundamental issues of regulatory compliance impacting our world today. The 20,000-word report includes exclusive interviews, detailed graphics, photos, videos, and more. Editorial Writing: What’s on your Mind?! It is not a case of precisely which crime we suspect, albeit there will be times when this is almost obvious, such as the fraud referenced above. 2020-09-30T18:20:00Z. The SARs referenced by media organizations reporting upon the leaks were submitted in compliance with legal obligations by multiple international banks. Often, less is more when writing a SAR, thereby facilitating the accurate, expedient, and succinct delivery of important financial crime intelligence while simultaneously protecting the author from unwanted and unjustified scrutiny at some time in the future. I am unable to answer the second question but will try to address the first. Connect with us to join the compliance conversation. He now applies his experience to the analysis and subsequent commentary of current compliance investigations and settlements. In every instance, an employee of the bank submitted the SAR because he/she suspected a crime was connected to the funds, customer, account, related parties, or a combination of these factors. Now it's time to assess your students' abilities to develop a well-reasoned argument with this end-of-year writing prompt, complete with pre-writing … Thus, if we are uncertain, we should seek to find some certainty, even if this means talking to the customer, or more likely having the relationship manager talk to the customer. This is a high interest topic in our area right now. Opinion writers need to establish credibility so that their audience will value their opinion. ‘FinCEN Files’ fallout: Where do banks go from here? Make this a center activity, or print an article from NewsELA for free! Jan 22, 2015 - Your students will learn the difference between opinion versus persuasion with this fun infographic about dogs. In another SAR, the writer suspected the transactions were part of a layering process, and in another instance the funds appeared to be round-tripping from an account through other accounts and back to the originating account. The “FinCEN Files” report raises the question: What should banks be doing to address the trillions of dollars’ worth of banking transactions that are facilitating criminal activity every year? Welcome to ComplianceWeek.com. Try to adhere to the facts, numbers, names, and addresses without expressing emotions or colorful opinions. Two full lessons to practice opinion writing (persuasive writing) with Thanksgiving-related focus questions.This product is a bundle of the following two resources:• Fact-Based Opinion Writing for Thanksgiving {Question #1}• Fact-Based Opinion Writing for … Understand what words mean. It’s important we understand with the “FinCEN Files” that the enemy is not a journalist, a regulator, or a banker. The leaks were illegal; nonetheless, they are now in the public domain. If suspicion has arisen because a regulator contacted the firm/bank and made enquiries about a customer, raise an alarm. Now I hear readers screaming in alarm because someone is proposing we ask a customer questions about a suspicious transaction. What you say matters as much as how you say it when filing a suspicious activity report (SAR). In others, it is the banks’ actions prior to the submission of the SAR. Whereas fraud is a crime, layering and round-tripping are not. Some will read the redacted narratives and ponder: what does it all mean, and what did the authorities do with the information? By way of example, it is always difficult to know the exact criminal origins of money flowing out of Russia, but at a minimum, there is likely to be some form of tax evasion. The correct use of words can avoid a lot of challenges and doubt at some later stage. Don’t have devices for each student? It’s all about the wording, and to some extent the investigation of the activity which gave rise to the SAR. For this lesson, we are going to be writing an opinion essay about whether or not children should have cell phones. At an almost alarming rate, students these days are unable to determine news writing from opinion writing. The damning revelations from the “FinCEN Files” leaks have once again put Europe and its supposed world-leading anti-money laundering rules under the spotlight. I hear some readers immediately challenge, “When do legitimate businesses engage in layering and round-tripping?” And there are a number of answers to this, many of which are logical and reasonable. So be bold; endeavor to be accurate; and do make reference to characteristics and features which fuel your suspicion. Join Compliance Week today and get full access to our six-chapter case study detailing cruise line Carnival’s tale of compliance redemption set against the backdrop of the coronavirus pandemic. Editorial Writing as a Catalyst for Discussion of Important Issues This lesson teaches students editorial-writing by making them decide what’s important. Ask a CCO: What will compliance look like in 5 years. These were bold and direct assertions. We must always articulate suspicion of a crime; after all, this is the very essence of the SAR and the wider AML regime. Due to COVID-19, we will be holding the 8th Annual Compliance Week Europe conference virtually this year on 11 November. There are times when it is both good and necessary to talk to customers about unusual transactions. Thus, I contend there are times when it is necessary to ask the customer questions. For this lesson, I shared a simple Pro/Con table like this one. We asked nine prominent chief compliance officers to look into their crystal balls, and all of them saw data and advanced technology playing a larger role in the future of the profession. The leaks will cause many to ponder what is taking place within an anti-money laundering (AML) regime that appears to be obsessed with reporting, gathering intelligence, and then appearing to do nothing to stop the laundering. The updates include daily lesson plans and so much more! ‘FinCEN Files’ show Europe’s AML efforts maybe aren’t so world class. Editorial. So, what’s the issue? The enemy is the money launderer, and this is where we need … Opinion Writing PowerPoint – Day Two Opinion Writing Prompt Review Writing Prompt. As it appears, there are too many SARs to allow authorities to properly investigate the suspicions/allegations articulated in each one. Keep in mind that one day, as in the case of Shah v HSBC, you may be cross-examined about your actions and words. Thankfully, they have all been carefully redacted prior to being shown in any broadcasts or publications, and the names of no bank employees have been exposed. Right now, I am not aware of my wife’s precise whereabouts, but I have no suspicions about her. Special report: Leadership in a time of unpredictable change, e-Book: Mind the Gap — Where Third-Party Risk Management Programs Fall Short, e-Book: Companies still wrestle with data privacy regulation, e-Book: Agile Lease Accounting During Uncertain Times. With the British Virgin Islands vowing its commitment to a beneficial ownership public register, financial crime expert Martin Woods turns his attention toward how the U.K. and U.S. are progressing in the space. The key word is suspicion; more pointedly, suspicion of a crime. Read our policy. Words are very important, because as the leaks demonstrate, one day they may be read by many people, including your customer. We’ve been writing opinion paragraphs during our Reading block to get us ready for the formal opinion essay we have coming up during our Writing … Having seen some of the SARs, I was struck by what was written, and in some cases I determined a SAR should not have been filed. Compliance has been taking some heat in the wake of the “FinCEN Files” reports, but it’s banks’ senior leadership that failed, not the folks filing all those SARs. In some instances, the reports have focused upon the actions taken by banks after the submission of the SARs. Within one particular SAR, the AML investigator/analyst asserted he/she could identify no lawful purpose for the transactions and suspected fraud. Moreover, it is important to ensure we use the correct words in the right way when drafting a SAR. If you are unable to find a Website for a corporate customer with a busy account, say so. In this week’s “Nailed It or Failed It,” we take down EY and JPMorgan Chase for apparently ignoring whistleblowers and give the SEC a nod for rewarding them. The recently published FinCEN leaks have revealed a huge SAR chasm to the general public, into which millions of suspicious activity reports are filed every year. The topic can certainly be tailored to fit the interests of the students in your area. ‘FinCEN Files’ highlight bank leadership flaws, not compliance flaws, EY allegedly flubbed Wirecard dealings worse than we thought, Progress on beneficial ownership key to AML fight. In my two Journalism I classes, I conducted a pre-assessment experiment where students evaluated a news article and opinion article from the local newspaper. In this lesson, your students learn how to establish themselves as authorities on their chosen writing topics. 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