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Basic AML Debugging.; 2 minutes to read; D; In this article. The AMLI Debugger supports two types of specialized commands: AMLI Debugger extensions and AMLI Debugger commands. When you are performing AML. We may also ask to see your driver’s license or other identifying documents. Reliance on Another Financial Institution A bank is permitted to rely on another financial institution (including an affiliate) to perform some or all of the elements of the CIP, if reliance is addressed in the CIP and the following criteria are met. Point mutations accounted for 73% of all drivers (3824 of 5234) (Fig. S2d in the Supplementary Appendix) and were often enriched in patients with AML classified as intermediate risk according to. Tracing, Stepping, and Running AML Code. If you want to trace through the code, you can turn on full tracing information by using the!amli set extension as follows: kd!amli set spewon verboseon traceon Now you can step through the AML. Drivers filed under: AML. RSS Feed for this tag 11 applications total Last updated: Nov 2nd 2013, 10:43 GMT. Toshiba Bluetooth ACPI Driver 9.0.0.2 for Windows 8.

Identification Documents are the backbone of most KYC and AML procedures. Here we explain this increasingly complex topic and show you how best to tackle it.

Identification documents are with us from the moment we’re born. Nationally issued ID cards, passports, visas, birth certificates and drivers licences help determine if we can drive a car, enter a foreign country and even – in some places – walk the streets.

As the requirements around KYC and AML continue to grow, an increasing number of businesses are compelled to identify, manage and authenticate centrally-issued identification documents. Know Your Customer processes often require businesses to collect a passport copy and authenticate its legitimacy before entering into a business relationship.

Keeping in mind that hundreds of identification documents exist, it’s unsurprising that the cost of KYC jumped by 19% in 2017 and around 16% in 2018. Not only do businesses need to be able to collect and authenticate current documents, but they also may have to analyze documents that were issued decades ago. The Kenyan ID card for example, does not expire and many different versions have been issued over the years.

For businesses this can be a huge headache and many use a compliance solution to help manage their ever-increasing regulatory burden. Regardless of whether you choose to tackle this problem yourself or not, the key is to be able to accurately check identification documents and reject those that are fraudulent. That’s what this article aims to help you with. Let’s dive in.

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What types of identification documents can typically be used for a KYC check?

Not all IDs are created equal, but it’s often tough to understand which can be used for KYC checks and which can’t. The US alone has 11 forms of identification that your prospective customers may attempt to use. These are:

• Ordinary Citizen’s Passport
• Diplomatic Passport
• Three different types of Service Passport
• Two types of Travel Document
• Visa
• Two different types of residency documents
• Work permit

The EU’s Prado database is an invaluable resource for this kind of information, providing not just a list of accepted documents, but also reference images and detailed security features. With that in mind, most businesses tend to limit the accepted identification documents to passports, ID cards and driving licenses.

What is a security feature?

One of the main reasons that nationally-issued identification documents are the gold standard for KYC checks, is that they typically include an array of sophisticated security features. These are designed to prevent convincing replicas being made, and help to ensure a higher likelihood of an ID being authentic.

When carrying out KYC checks, businesses need to know which security feature should be present on the ID in question. For example, a standard US passport should comprise 28 pages, and be 88mm wide as well as 125mm high. It should also possess the following security features:

1. Inside back cover
   • Printing technique – guilloches / fine line patterns
2. Biodata page
   • Printing technique – optically variable ink
   • Facial image
   • Laminate – hologram
   • UV feature
3. Inner page
   • Substrate
   • Watermark
   • UV feature – fluorescent overprint

Of course all of these are important when identifying a customer in person, but most KYC checks are completed online – meaning that prospective customers upload a photo of the ID. In these cases it becomes very difficult to authenticate documents properly because most of the security features will simply not be clearly visible.

Unfortunately, mainstream photo editing solutions have made it incredibly easy to replicate the shape and design of an ID. Therefore, simply asking customers to upload an image showing a single page can only be considered the bare minimum in terms of KYC and AML.

To combat this, countries like Germany have introduced video identification procedures which require businesses to set up live video calls, during which the identification document is checked more rigorously.

This is also why banks typically require the customer to visit the branch before opening an account. Regardless of which form of identification you choose – image upload, video call or in-person meeting – make sure to take your customer due diligence duties seriously.

What are the most common security features and what do they look like?

We’ve listed a few prominent security features above, but it makes sense to look at the most common ones here:

UV Light – brightly glowing image and lettering which is only visible under UV Light. Source

Hologram – intricate shapes which shine and glimmer with varying lighting conditions. Source

Watermark – a faint design that is visible both when held against light and when not. Source

Numbering – a string of numbers typically punctured into the material. Source

Problematic identification documents

With the dawn of the Internet age, customers are no longer limited by geographic location. These days, a small business in Philadelphia may service customers from Indonesia, India and Australia.

From an AML and KYC perspective, this introduces new challenges. For one thing, different countries issue different forms of ID, and not all of them are compliant with internationally-recognized best practices.

The Italian ID card for example consists of a simple, folded piece of paper and almost no security features. This makes it incredibly easy to fake, and it’s almost impossible to detect fraudulent documents via a simple image upload.

Passports from Greece can also present a challenge because there are currently three different versions in circulation – all of which are considered valid. The first one was issued in 2011 and contains printing techniques, substrates and UV features. The next one was issued in 2012 and is almost identical to the previous version except that it has a UV feature on the inside back cover, which is not present in the 2011 version. Finally, the third iteration was issued in 2014 and features a different hologram near the facial image.

A similar problem arises with IDs from the other side of the world: Indonesian passports issued prior to 2014 use laminated paper instead of polycarbonate and are therefore easy to forge. This is worth keeping in mind when asking the customer to complete your KYC procedure. Ideally ask for Indonesian passports issued after 2014.

Additionally, document fraud is a key component of organized crime and terrorism. There is a whole subset of criminal activity that is involved in stealing and faking passports in order to supply them to the criminal market. IDs that are easier to forge or easier to get a hold of are therefore more commonly used by criminals attempting to pursue malicious activity. It is vital that you protect your business from criminals aiming to misuse the business relationship.

Below you can see how the number of lost and stolen travel documents has escalated since 2010:

From a KYC perspective, stolen documents are particularly difficult to detect, as they are usually genuine and have been misappropriated from law-abiding people, or even seized from civilians or combatants in conflict areas.

To counter the threat of both misappropriated and forged documentation, it will be necessary to implement enhanced due diligence procedures and monitor customer behaviour closely.

Automating the identification document checks

As you can see it is becoming increasingly complicated to collect, authenticate and manage identification documents. A vast number of IDs exist and the regulatory landscape around compliance keeps shifting. Today, KYC procedures are more cost-intensive than ever before and it seems like this trend will endure well into the next decade.

With this in mind, it’s often no longer feasible to build and operate a KYC solution in-house. The development time combined with the time it takes to bring in trained personnel is simply not available to 99% of businesses, making alternative solutions ever more necessary.

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That is why dedicated low-cost compliance solutions are more popular than ever. These can often automate the collection phase and give you the tools you need to manage customer IDs securely.

An additional advantage of these kinds of compliance solutions is that they often adapt to regulatory changes much faster than an ordinary business can. When a significant change, like the introduction of GDPR, occurs, companies like KYC-Chain are the first to react, updating their processes and best practices. This allows you to focus on your business and what you do best, while the intricacies of KYC compliance are handled and maintained by people who specialize in it.

Finally, working with a vendor also means that your ID checks will employ the latest technology. If your business was to build an automated solution in-house you would likely not have the time or resources to update it when new technology emerges – like biometric data. Third party vendors on the other hand, are often at the forefront of this kind of technological innovation.

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Assessing Inherent BSA/AML Risk at Community Banks
by Bronwen Macro, BSA/AML Risk Coordinator, Federal Reserve Bank of San Francisco

Every community bank faces some degree of inherent Bank Secrecy Act/Anti-Money Laundering (BSA/AML) risk. This inherent risk comes from a bank's productsand services, customers and entities, and the geographical locations in which the institution and its customers operate. Effective BSA/AML complianceprograms incorporate appropriate controls to mitigate these risks. However, with the rapid speed of innovation in the banking industry and a continuedregulatory focus on BSA/AML compliance, accurately assessing inherent BSA/AML risk is an important first step in the BSA/AML compliance process.

This article is intended to help community bankers understand potential indicators that can be indicative of elevated levels of inherent BSA/AML risk andheightened legal and compliance risk that may bring greater regulatory focus.¹ The article begins by reviewing some of the factors regulatorsmay assess to identify institutions' inherent BSA/AML risk and discussing the evolving nature of that risk. It then offers observations on keycharacteristics of effective risk identification programs and examiner expectations for analysis and mitigation of community bank BSA/AML compliance risks.It concludes with a specific discussion of two important areas: (1) setting the right compliance tone at the top of the organization and (2) including theBSA compliance officer in new product development discussions.

Evolving Nature of BSA/AML Risk

Over the past 40 years, both the BSA/AML regulatory environment and the financial services environment have evolved. When the Bank Secrecy Act was enactedin 1970, the primary intent was to combat drug trafficking, with regulations focused on the domestic banking system and on cash transactions, which weremost often conducted face-to-face. In 2001, with the passage of the USA PATRIOT Act, the AML framework in the United States and the BSA itself weresignificantly amended in recognition of the changed landscape of financial crimes and systems. BSA/AML regulatory requirements were expanded to confront abroader set of criminal activities, including terrorist financing. Regulations address the complex financial services environment that has continued toevolve since the BSA was first enacted; this environment now relies to a large extent on fast-paced, anonymous transactions within a globally intertwinedfinancial system.

Increasingly complex product offerings complicate risk assessment activities, as these offerings, by their very nature, are more difficult to assess thantraditional banking products and services. For example, electronic banking systems, the purpose of which are to expedite the delivery of banking productsand services, have replaced traditional face-to-face contact with remote, electronic account opening and transaction initiation. Likewise, electronic cash,including mobile payments and pre-paid cards, provide similar conveniences but also greater risks associated with reduced transparency of transactions.

While these innovations deliver numerous benefits to customers and bankers, the change in delivery systems often increases the risks of what previouslywere lower-risk services. For example, online account openings present challenges in verifying the account holder's true identity and geographic origin orbusiness footprint; these challenges are further exacerbated by the almost instantaneous processing and settlement of transactions. All these issues affectan institution's ability to predict the type and frequency of transactions the customer is likely to make; without a firm understanding of the customer'srisk profile, monitoring for suspicious activity and, by extension, the reporting of suspicious activity can be more challenging.

In addition to the fast pace of innovation, banks are facing a sustained low interest rate environment, and many institutions find themselves facing addedpressure to offer new and competitive services, sometimes without adequately reviewing and assessing the risk of these services. Implementation of theseproducts without appropriate vetting can mean that the inherent risk profile of the institution increases without a commensurate enhancement to riskmitigants. At the same time, the low interest rate environment also introduces pressure to cut costs, and operational areas such as compliance are oftenprime targets for trimming. Institutions with increasing BSA/AML risk profiles and dwindling resources may be vulnerable to having weakened BSA/AMLprograms.

As BSA/AML risk increased, the financial crisis may have diverted some management teams' focus away from BSA/AML as they addressed their institutions'financial viability. Consequently, some BSA/AML programs became stagnant and did not keep pace with the institutions' subsequent growth, expansion, andchanging risk profile.

Throughout this time, the core BSA/AML program elements have remained the same; however, as banking products and services became more complex andelectronic in nature, accurately assessing these risks became even more challenging and critical. At the same time, the consequences of noncompliance havebecome more severe.

Importance of Proper Risk Assessment

Identifying the inherent BSA/AML risk of an institution's products and services, customers and entities, and the geographic locations in which theinstitution and its customers operate is the first step in developing an effective BSA/AML compliance program. It is only after these risks are identifiedand analyzed that an institution can begin to develop a compliance program tailored to and commensurate with the risk profile of the institution.Understanding the inherent risk faced by the institution will determine how it approaches the four pillars² of BSA compliance. For example, thelevel of inherent risk should determine (1) the nature and extent of internal controls, (2) the scope of independent testing, (3) the skills and expertiserequired of the BSA compliance officer, and (4) the focus of and approach to training. The board of directors and senior management at community banksshould develop compliance programs tailored to the specific inherent risks of their institutions. Likewise, the nature and extent of mitigating controls,including investments in infrastructure and human resources, should be commensurate with a bank's risk profile.

The stakes for failing to comply with BSA/AML regulations have never been higher. Not only has noncompliance in some recent cases resulted in significantfines and penalties, but weak programs can also stall expansionary plans. In 2012, various regulatory agencies assessed fines and penalties against anumber of institutions that in aggregate exceeded $3.2 billion;³ this represented the largest amount in BSA/AML and Office of Foreign AssetsControl penalties ever imposed over a one-year period. In addition to the monetary penalties and fines, these banks incurred significant expensesassociated with remediating their compliance programs, such as increases in staffing and investments in technology, as well as related legal expenses. Buteven if compliance program shortcomings are not significant enough to warrant monetary penalties, material deficiencies that are deemed to make a programless than satisfactory can curtail an institution's expansionary activities. Section 327 of the USA PATRIOT Act requires federal banking agencies toconsider an institution's BSA/AML compliance program when reviewing a bank's application. The Board of Governors of the Federal Reserve System (Board) haspublished a supervisory letter on Section 327 for institutions submitting applications to the Board that states:

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On a case-by-case basis, depending on information contained in examination reports and obtained from other regulators, further information about theeffectiveness of an applicant's anti-money laundering activities may be required from the applicant to complete the Federal Reserve's analysis of anapplication. The applications record maintained by the Board and the Reserve Banks should continue to include documentation relating to the review of anapplicant's efforts to combat money laundering activities, including information about contacts with other regulators.⁴

Thus, inadequate BSA/AML compliance could adversely affect a banking application.

Most of the recent high-profile enforcement actions have focused on internal control deficiencies at large, globally active financial institutions.Although not often in the public realm, deficiencies at community banks have also been noted, and similar to findings at the large institutions, weaknessesat smaller institutions often involve a deficient customer risk-rating process. For both large and small institutions, the ability to identify high-riskcustomers directly impacts the efficacy of monitoring regimes; if risk identification and follow-through are weak, institutions may fail to file SuspiciousActivity Reports when necessary.

The problem often lies in inadequate customer due diligence because banks may not fully understand their customers' business. For example, a money servicesbusiness (MSB) engaged solely in payroll check cashing likely poses less risk than an MSB providing multiple lines of products, including high volumes ofcross-border money transfers. Understanding the specifics of the business and making distinctions between high- and low-risk customers are crucial firststeps in being able to calibrate risk monitoring and identify and report any suspicious activity.

Key Categories of BSA/AML Risk forCommunity Banks

Inherent BSA/AML risk falls into three main categories: (1) products and services, (2) customers and entities, and (3) geographic location. The first stepin understanding the inherent risk is to identify the extent to which these categories present risk for the institution; the second step is to analyzethese risks more thoroughly so that the true nature of the risk is known and appropriate controls can be developed.

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Within the three categories, certain characteristics present higher levels of inherent BSA/AML risk. Specifically, customers, products, and services thatobscure financial transparency, allow for anonymity, or include multiple parties along the payment chain are especially vulnerable to money laundering. Forexample, financial intermediaries, such as third-party payment processors, MSBs, or foreign correspondents, pose higher risks because banks lack directaccess to, or knowledge of, their customers' customers; due diligence and suspicious activity monitoring efforts are thus more challenging and morecritical for mitigating risks. Similarly, prepaid cards and virtual currencies both offer anonymity and can involve many parties, again making it difficultfor banks to identify specific customer activity and determine whether that activity is suspicious. As such, community bank management should ask itselfseveral questions to help identify some of these areas of heightened BSA/AML risk.

Higher-Risk Products and Services

• Do we have significant volumes of electronic payments, such as wire transfers, ACH, prepaid cards, and remittances?
• Do our customers actively engage in, or have we recently implemented, electronic banking services, such as remote deposit capture, online account opening, and/or Internet transactions?
• Do we provide services to third-party payment processors or senders?

Higher-Risk Customers and Entities

• Do we have a significant portfolio of cash-intensive business customers, such as privately owned ATMs or convenience, liquor, or retail stores?
• Does our customer base include foreign entities, such as financial institutions (banks and foreign money service providers, including exchange houses, money transmitters, etc.), corporations, and/or individuals?
• Do we have significant business related to nonbank financial institutions, including MSBs and casinos?
• Do we have a significant number of professional service provider customers, including attorneys, accountants, real estate brokers, etc.?
• Do we maintain accounts for domestic and/or foreign nongovernmental organizations?
• Does our customer base include a significant number of politically exposed persons?

Higher-Risk Geographic Locations

• Do our customers engage in or process transactions involving international locations identified by the U.S. State and/or Treasury Departments, the Financial Action Task Force, or other international bodies as having strategic deficiencies in their countries' AML frameworks or being susceptible to corruption, and/or geographic locations outside of our normal business area?
• Are any of our customers located in, or do they conduct transactions with, offshore financial centers?
• Do we maintain branches in or have significant customer populations located within domestic locales designated as High Intensity Drug Trafficking Areas and/or High Intensity Financial Crimes Areas?

Once the areas of inherent risk are identified, further analysis is needed to fully understand the risks of each category. For example, a first level ofanalysis may include the review of data pertaining to the volume of transactions and the number of higher-risk customers. Pairing these data with customerdue diligence information, such as the purpose of the account, the products and services used, transaction and dollar volumes, and jurisdictions involved,allows management to make necessary distinctions between seemingly similar customers. For example, a local doctor who has been a longstanding customer anduses remote deposit capture to collect low-dollar payments for office visits from her customers likely presents a lower level of risk than an MSB thatdeals with customers and parties located in a foreign jurisdiction. After conducting such analyses, management is better equipped to build monitoringsystems calibrated to the specific risks of the bank's customers.

Getting It Right

How can management ensure that the bank is adequately assessing inherent risk? Institutions with strong BSA/AML risk assessment programs take a dynamicapproach to risk assessment, as opposed to viewing it as a static exercise only performed once every few years. These institutions also ensure that the BSAcompliance officer is a fixture in any new product discussion. Finally, the board of directors and senior management at these institutions set the rightcompliance tone from the top by demonstrating the importance of understanding, monitoring, and controlling BSA risk.

A dynamic BSA/AML program is one that revisits its risk assessment regularly, or even on an ongoing basis, depending on its risk profile, by comparing theassessment with the bank's current products, service offerings, and customer mix. A good assessment appropriately considers the products, services,customers, transactions, and jurisdictions that currently pose risks to the institution. If the institution has recently implemented new products andservices, these risks should be reflected in the risk assessment and control environment. Integral to this process is a strong 'know your customer' programin which customer information is collected on an ongoing basis to maintain up-to-date information on activity and product utilization and the associatedrisks. Not only is this practice good for BSA/AML compliance purposes, it is also good for business. Building customer relationships, especially with smallbusinesses, includes demonstrating a current understanding of the customer's specific business and industry and showing that the bank can anticipate andfulfill the customer's banking needs as they arise.

Along with periodic updates to the risk assessment, examiners expect banks to perform a review of the control framework and make updates and enhancementsto address any gaps presented by new or heightened risks. This includes reevaluating and recalibrating automated monitoring systems to ensure that theycontinue to make sense for the types of transactions the bank is trying to identify or control, especially given the bank's updated risk profile.

Another important step in the inherent risk assessment process is to include the BSA compliance officer in any new product or service developmentactivities.⁵ It is crucial that the BSA compliance officer be involved from the very beginning so that potential risks are identified andunderstood early, prior to implementation. As new technologies are developed, the associated risks are often unknown. These risks have the potential toaffect not only inherent risk but also the control framework. In this regard, management should consider the following questions:

• How does the new product or service affect our risk profile?
• What steps need to be taken to appropriately mitigate the risks?
• Do we have the expertise, capacity, and compliance resources to take on the new product or service and/or the various associated service providers?

These types of questions should be discussed with all appropriate stakeholders, and adequate planning should be in place before any new product or serviceis implemented.

Finally, effective BSA/AML compliance programs reflect a strong commitment to compliance from the board of directors and senior management. This extends toall aspects of the program, including risk identification and analysis. Discussions about BSA/AML risk should be conducted at all levels of theorganization, including the board of directors, executive management, line management, and staff. Assigning proper priority to the BSA compliance programalso includes investing in compliance talent and resources, empowering compliance officers with the necessary authority to resolve identified issues, andcreating a formal mechanism for reporting on BSA/AML risks and issues to the highest levels of the organization.

Conclusion

Understanding an institution's inherent risk is the first step in developing a strong BSA/AML compliance program, and getting it right has never been morechallenging. At the same time, the stakes for noncompliance have increased. Banks with strong BSA/AML compliance programs have made ongoing risk assessmenta priority for their institutions, included their BSA compliance officer in new product development discussions, and set the right tone at the top of theorganization.

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• ¹ While this article focuses on community banks, these principles are relevant to banks of all sizes.
• ² BSA/AML programs must include the following minimum requirements (also known as the four pillars): (1) a system of internal controls, (2) independent testing of BSA/AML compliance, (3) designation of an individual or individuals responsible for managing BSA compliance (BSA compliance officer), and (4) training for appropriate personnel.
• ³ See details of fines and penalties assessed in 2012 by OFAC at www.treasury.gov/resource-center/sanctions/CivPen/Pages/2012.aspx; FinCEN at www.fincen.gov/news_room/nr/; and the Federal Reserve at www.federalreserve.gov/newsevents/press/enforcement/20121210a.htm.
• ⁴ See SR Letter 02-8, 'Implementation of Section 327 of the USA Patriot Act in the Applications Process,' March 20, 2002, at www.federalreserve.gov/boarddocs/srletters/2002/sr0208.htm.
• ⁵ For a more expansive discussion of best practices around new product development, reference 'Considerations When Introducing a New Product or Service at a Community Bank,' Community Banking Connections, First Quarter 2013, available at www.cbcfrs.org/articles/2013/Q1/Considerations-When-Introducing-A-New-Product.