FinCEN CDD Final Rule Tightens Screws on Name-Screening

The final version of FinCEN’s CDD requirements for financial institutions have now been issued, and they are already the subject of much discussion among AML/KYC practitioners.  Much of this discussion has to date been devoted to risk models and risk-containment procedures that implement these models. Largely overlooked in the rush …

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Are You Storing Your AML/KYC Data in the Bed of Procrustes?

There’s no substitute for knowing… In previous posts, I’ve attempted to convey some sense of the linguistic and cultural diversity that personal names exhibit, especially when these names are converted from other writing systems and social contexts into the Roman (A-Z) alphabet and the naming system that predominates in the …

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From the headlines to your AML/KYC system: the strange case of Mr. Wu

Breaking News That You Can Use Recently, all the major news channels carried a high-profile story about a Chinese businessman, Ng Lap Seng, who was arrested by the FBI for financial crimes, on the very same day that the Chinese President, Xi Jinping, arrived in Seattle, to begin his U.S. …

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