Information Security

Phone Scams For Everyone

11 Jul 2017

In the past day or two I’ve received a few alarming voicemails claiming potential legal actions and even threatening that the police will come to arrest me. Some claimed to be from the IRS, others were more vague. Anyone’s initial reaction is great concern – no one wants to be subject of a mysterious debt collection, a criminal investigation, or p...

Financial Services Regulation

Banking Marijuana Related Businesses

26 Jun 2017

In the past I've written in other venues I’ve written a good bit about banking marijuana related businesses (MRBs) – but that was in the past, well before the 2016 election in the US. Needless to say, a lot has changed. The focus of my writing then was centered around the 2013 Cole Memo and subsequent guidance from FinCEN in 2014, which laid out...

What does Robotic Process Automation Really Mean

16 Jun 2017

There have been a number of vendors getting in to Robotic Process Automation (RPA) to address some of the tedious aspects of AML compliance. As many know, even the best AML compliance systems tend to produce large numbers of false positives that analysts must review and clear. Large backlogs can lead to enforcement actions and generally lead to hi...