Compliance / Fraud / Policies & Procedures / Technical Writing

My career took an interesting detour into the regulatory compliance world - mostly Anti-Money Laundering (AML) - for several years. Although I had direct responsibility for several compliance functions at Western Union and worked as Chief Compliance Officer at PayLease, much of my work still revolved around communications.

I spent quite a bit of time on outreach, articulating aspects of my companies' compliance functions to state and federal regulators, banking partners and customers. My writing and public speaking abilities helped me deliver our messaging with great clarity.

Also, I took the time to learn the AML world in-depth and earned the Certified Anti-Money Laundering Specialist (CAMS) designation, which lent greater credibility to the mix. Combined with my deep knowledge of the business and operational processes, the story was very persuasive.

Based on my compliance experience, I also wrote policies & procedures and risk assessments for Western Union and PayLease, and reviewed/edited stress test and risk assessment documentation, and Service Organization Control (SOC) reports for CoBank. 

I can provide redacted examples of P&Ps that I have written upon request.

Social Engineering

Social engineering manifests in many different ways and through many oddly named fraud techniques, including phishing, vishing, smishing and others. The foundation of social engineering - and the reason fraudsters succeed - is through the ability to manipulate a target into believing that an email or a telephone request is legitimate. This is usually accomplished by directing the victim to respond with a sense of urgency to the new contact information cited in the email or phone call.

Cyber Account Takeover

This quarter, we turn from describing specific scams to explaining how some of these scams are carried out. One of the common ways that fraudsters commit these scams is through cyber account takeover - the ability to take control of an online account by stealing a user's login credentials or hijacking an online session. Once in control of an account, a fraudster steals funds by initiating outgoing wires or ACH transactions, which can be extremely difficult - if not impossible - to recover if not identified timely.

CEO Impersonation Scam

One of the most successful fraud techniques targeting businesses today is known as the "CEO Email Scam." The scammer effectively impersonates a company's CEO or other high-level executive by gaining access to or "spoofing" his or her email account, and requesting a wire transfer. According to the FBI, between October 2013 and August 2015, over 7,000 U.S. businesses fell prey to this scam, netting criminals an estimated $747 million. The scam has been reported in all 50 states and in 79 countries.

Human Trafficking vs. Human Smuggling

The 2009 Best Picture and ‘feel good movie of the decade,’ Slumdog Millionaire, is based on a dark and sordid issue. Recall that before the lead character, Jamal, wins millions on a TV game show, he escaped the grip of gangsters who brutally blinded children to make them more ‘appealing’ as indentured street beggars. Similarly, Jamal’s friend, Latika, would be forced into prostitution. This is human trafficking. And the movie’s happy ending is not the case for millions of vulnerable women and children worldwide. Then there is human smuggling, which involves the illegal movement of people across international borders. Human smuggling sounds similar to human trafficking but they are actually two different crimes with very different outcomes. Migrants seek and pay for the services of human smugglers. Human trafficking— which is more akin to slavery—is a truly heinous crime that deprives its victims of their most basic human rights.

One company’s approach to mitigating prepaid card risks

In this part of the program it’s important to remember compliance’s interaction with marketing: prepaid card providers should not oversell such card attributes as anonymity. Most consumers are reasonable people and understand the need to balance privacy and transparency to ensure the safety of the financial system. A marketing pitch based entirely on anonymity is bound to attract the wrong element.

Transaction Monitoring & Reporting for Money Services Businesses

By thoroughly understanding the risks associated with various consumers, services and geographies, MSBs can develop an effective suspicious review mechanism. This mechanism – part machine, part human and driven fully by management’s unwavering commitment to anti-money laundering compliance – can help ensure that MSBs can address and mitigate risks effectively as we as provide law enforcement with meaningful information to protect our nation’s financial system.
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