Latest opinions that Frank Cummings has shared on Finextra

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Frank Cummings

CEO

AML Partners LLC

Member since

02 Jun 2022

Location

Concord

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Frank's opinions

The Legitimacy Life-Cycle – All Risk Mitigated

The Legitimacy Life-Cycle – All Behavioral Risk Mitigated Lifecycle management has become an AML Compliance buzzword. But it’s often just new wrapping on the same old package. The Legitimacy Lifecycle, in sharp contrast, looks at the lifecycle challenge with a comprehensive emphasis on Risk relevance and Risk mitigation. Unlike other lifecycle-mana...

28 October 2022 /crime RegTech

Hosted Managed Services for KYC/AML, really?

Hosted Managed Services--A crucial option for institutions striving to maximize RegTech capabilities, focus on core business Custom fit. Tailored. Bespoke. Made to order. If you’ve been tracking trends in RegTech and GRC solutions, you might recognize how those terms describe an innovative new direction: hosted managed services. Prior to the pande...

12 September 2022 /crime RegTech

What AML rules should I run

That’s the question I get asked most often by AML Compliance colleagues--and it’s the question that worries me the most. That question tells me that the financial institution likely has a major problem with its Risk-based Approach. I’ve been doing AML for close to 20 years now, the first seven implementing “other people’s software” or just Ops wo...

06 September 2022

I Am Not a Boss or a Leader; I Am an Enabler

I Am Not a Boss or a Leader; I Am an Enabler I have been around the block far more times than I would like to count. I have been led, and I have led. And I have come to realize that neither will make you truly successful. Leading organizations large or small does not mean you are successful. It means you played the game well enough to be allowed to...

23 August 2022 /crime RegTech

Know Your World - Closing the circle of due diligence

Financial institutions globally have enhanced Customer Due Diligence/Know Your Customer procedures to the point of pure art. In some cases, institutions collect over 600 individual fields of information, and some use upwards of 14 data interfaces to support a mix of internal systems and external data providers. It’s getting to the point where we

19 August 2022 /crime RegTech

Digital Transformation Time--Again?

'Digital Transformation' sellers—a.k.a. the “cookie-jar consultants”--are at it again It’s happening again: Claims of digital-transformations-solve-all-problems are everywhere. I don’t want to sound too boomer-ish, but we have been down this tech-solves-all road a couple times before. And many leaders will believe the hype: Transform your digit

29 July 2022 /regulation RegTech

ESG--The People's Regulator?

Environmental and Social Governance may force different decision-making in ethical gray areas of revenue streams Unlike Governance, Risk and Compliance (GRC), Environmental and Social Governance (ESG) prioritizes informing the public on how corporations handle their environmental and social obligations. Regulatory reporting remains a feature o

20 July 2022 /regulation RegTech

If you work at a Financial Institution you are going to Hate this Blog

We need to monitor more than just customers. I have in the past discussed what I call Behavioral Analytics. Behavioral Analytics leverage automated comparisons between data-based predicted behaviors and customers’ actual behaviors. When combined with Rule-Based Systems, Behavioral Analytics can prevent criminal schemes even before they begin. S

14 July 2022 /crime RegTech

Headline: Mass-shooting horrors demand better response—Metadata a way forward?

July 4 revelers in Highland Park, IL, experienced another mass-casualty shooting in America. Stunningly, at this point it’s no longer surprising to see these news alerts. Something has to change. I wrote here a couple weeks ago that RegTech behavior-monitoring technologies have the potential to warn of impending violence—like school shootings and ...

05 July 2022 /crime /predictions RegTech

Major Increase in Financial Crimes on the horizon.

Expect a spike in Financial Crime. Here’s why and how you can prepare for it. Why expect a spike in financial crime? It’s the economy, of course. We are on the doorstep of recession, and it’s hard to imagine a gimmick or politician who can stop it now. For those of us who specialize in AML Compliance and related Risk, economic recession strongly ...

01 July 2022 /regulation /crime RegTech