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Blogs by Ben Knieff

June 23, 2016

I had the opportunity to be on a panel at an event hosted by IBM in New York last week focused on emerging fraud issues. Participants ranged from fraud managers at financial institutions to data scientists from various vendors. It was a fantastically open and interactive dialogue that brought up many issues, none of which we easily resolved. One of the really interesting conversations was around the use of biometrics and their impacts on privacy.

January 26, 2016

Previous posts in this series looked at the FinCEN guidance’s potential impact to institutions serving marijuana-based businesses. The first took a high-level view of how the guidance impacts institutions and the decisions that need to be made.

January 19, 2016

The FinCEN guidance provides substantial clarification around filing SARs and CTRs for marijuana-based businesses. In essence, the guidance states institutions should file SARs and CTRs as if the customer is an illegal business, though not necessarily terminate the account. This could easily cause some confusion, since this deviates from the normal practices; in most cases, an entity known to be operating illegally would be terminated along with the SAR filing.

January 14, 2016
Transaction monitoring

Most organizations have rather mature and effective transaction monitoring systems in place, but they may not be ready for these new types of businesses and their transaction patterns. For example, with a marijuana dispensary or retailer, many of their customers choose to pay in cash, which will result in large daily cash deposits (more on this later). Transaction monitoring systems will need to accommodate differences in behavior with this sort of business.

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