Greg Ruppert, a legal attaché for the Federal Bureau of Investigation in Berlin, spoke to Larissa Bernardes about the importance of getting the who, what, where, when and why of a customer's transactions.
Compliance officers may do well by borrowing from the pages of law enforcement agents and private investigators in performing due diligence on clients with offshore holdings, according to consultants.
Even as banks buy and operate expensive filtering systems to block transactions from individuals and companies on economic sanctions lists, financial regulators are increasingly inquiring about another group: customers previously booted for suspicious activity or actual crimes, say former bankers.
With multi-million dollar AML penalties fresh in their memories, financial institutions are looking more closely at their private banking clients and closing riskier accounts.
The $1.1 billion sale to U.K. bank Standard Chartered PLC follows enforcement actions issued in August requiring American Express Bank Ltd., the American Express private banking subsidiary, to pay $65 million in penalties and acknowledge its responsibility for AML and Bank Secrecy Act failures.
The private banking unit is overseen by the company's Miami-based American Express Bank International, and has been plagued by anti-money laundering related regulatory trouble for more than a decade.
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