🔥 🚩A multi-part 🔍analysis of #OFACs recent settlement with TD Bank🔥 🚩. The series of short 1 minute videos analyzes the settlement details, prevention methods to avoid these scenarios, and lessons learned. (Below is Episode 1 of 8.) Note: Link to other videos in Comments.
🔥 🚩Are you familiar with the TD Bank OFAC settlement from December?🔥 🚩 I have prepared a series of short videos that analyze the settlement details, prevention methods to avoid these scenarios, and lessons learned. (Below is Episode 1 of 8.)
🎧 🎬 To Watch The Video 🎬 🎧
If you prefer to watch this at your leisure, feel free to follow Noe Compliance on 🎵 TikTok: https://www.tiktok.com/@noecompliance or refer to the comments for links to the rest of the 🎬videos.
💥Part 1💥: Details of the Settlement pertaining to the Narcotics Kingpin. The SDN was able to open her account and evade detection for multiple years as a result of human error.
💥Part 2💥: Episodes 2, 3 and 4 cover “Questions that Come to Mind” where I analyze various aspects and provide insights on how you can prevent these at your institution using resources you already have. Episode 2 focuses on preventing the human error that led to improper closure of sanctions alerts over 4 years.
💥Part 3 Focuses on💥 earlier detection of human error (i.e. monitoring controls at the analyst level) to improper handling of high quality matches that are likely true matches or at least worthy of escalation.
💥Part 4 Focuses on💥 creating detection of unexpected account changes (i.e. Account level controls) to immediately detect inadvertent systemically triggered re-opening of blocked accounts.
💥Part 5 Focuses on💥 Updates to your training curriculum that will help you 👀prevent👀 falling victim to the same human/analyst errors that led to TD Bank’s OFAC settlement.
💥Part 6 Focuses on💥 Sanctions Screening Filters and why it is important to 👀test👀 your screening filters on a continuous basis and ensure you are able to detect the same scenarios mentioned in OFAC settlement letters. And, 🚩Yes,🚩 SDNs do modify their name to evade detection.
💥Part 7 Focuses on💥 👀SDNs having US addresses.👀 In fact, there are 😱73😱 entries on the OFAC list with a US address📍. Of those US addresses, half are in FL. And, you guessed it, of those Florida addresses, most are located in 🚩Miami, FL.🚩 Coincidentally the same location as the bank named in this OFAC settlement.😜
💥Part 8 Focuses on💥 using free tools such as a 👀Risk Bow Tie Analysis👀 to identify 😱blind-spots and vulnerabilities😱 within your compliance program. By identifying all of the 🚩risks/pitfalls🚩 your program must avoid, and then mapping out potential causes, controls, mitigants, and post-facto remediation requirements you will be able to minimize reputational risks (and penalties) to your institution as well as create a best-in-class program that will be complimented by your regulators.
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