Companies offering innovative products, especially those in fintech, are finding that answering questions regarding when to bring on a CCO and recruiting the right person, particularly in this tight labor market, is a difficult and frustrating process. Furthermore, many companies find that hiring a qualified CCO who understands the business and fits with the existing team is going to come at a significant expense that may frustrate the objectives of a growing business. In this article we summarize a few thoughts on why, when, and how to bring on a CCO that fits the company’s size and risk-profile.
John will be moderating a panel discussing how companies should approach due diligence and selecting artificial intelligence regtech solutions, particularly in the financial crimes space. Topics include:
Reviewing priorities of AML and FCC operations to determine functions such as transaction monitoring or investigations conducive to AI integration and capabilities
Mapping an AI infrastructure that addresses issues such as storage, legacy system compatibility and scalability to pinpoint and vet vendors best suited to fulfill institutional needs
Auditing post-integration processes to determine operating outcomes and efficiencies in areas such as false positive reduction or other metrics and identify and rectify systemic deficiencies
The Financial Action Task Force (FATF) is little known among many but plays a powerful role in protecting the global financial system. Founded over 30 years ago by the members of the G7, the group was intended to bring the most advanced economies in the world together to explore and share how they were each addressing money laundering. Much has changed in financial services in the past 30 years but what was observed then - the globalization of financial services and ability to arbitrage regulatory regimes - has only accelerated. That leads us to FATF’s recently issued guidance regarding virtual currencies and the bottom line is the document makes explicit and public what has been communicated to members of the virtual currency industry for years, with particular emphasis on the "travel rule."
As part of its efforts to support responsible innovation, the OCC recently announced the creation of a pilot program for new and innovative products and services. The OCC has considered the idea of a pilot program since it first announced the creation of the Office of Innovation in October 2016, so this development has been a long time in the making. In this article we summarize several components of the pilot program, including the opportunity for banks and their third-party partners to seek regulatory input in the pre-launch stage of a product or service.
On May 24th, the Financial Crimes Enforcement Network (FinCEN) announced its new Innovation Hours Program. The new program is designed to facilitate innovative approaches to combating money laundering and terrorist financing. In its announcement, FinCEN stated the program is intended to provide opportunities for both financial institutions and financial technology (FinTech) companies to discuss Bank Secrecy Act (BSA)-related innovations. In this article we summarize the program and provide useful insights for completing the application form.