The SAR Trend Review Q1 2018

A letter from our VP of Compliance and Financial Crimes Solutions

Dear Readers,

Earlier this week, Enigma hosted an ACAMS-NY Chapter event, C-AML: Exploring the New Frontier of Crypto-AML. As I engaged with two hundred other compliance professionals, it became abundantly clear that this is an important new frontier for AML. In fact, a small survey of ACAMS New York chapter members revealed that while 75% of our peers anticipate that cryptocurrency will affect their company in the future, only 33% believe they are proficient in cryptocurrency compliance. Much of the evening’s discussion concerned challenges around identifying and connecting relevant data related to cryptocurrency transactions to better manage AML risks.

While we wait for much-needed guidance in this largely uncharted territory, our compliance and financial crime teams are proactively trying to get a handle on how to think about cryptocurrency in the context of their specific programs. One of the biggest unknowns is how and when to incorporate an effective transaction monitoring approach into AML programs. I have to re-iterate a message we’ve often heard: that the answer is truly in the data. You just need to responsibly get at it.

The demand should no longer be to simply have more data, but rather to have the right data with the needed context to surface actionable signal.

This is core to our mission at Enigma. That’s why we’ve made it a priority not only to understand FinCEN’s SAR data, but also to share the findings with you.

Also, through our special report section, we’ve incorporated our founding principles that public data should be fully leveraged to deepen knowledge to enrich our day to day. In this report, we highlight the often overlooked precious metals industry, specifically gold, as a means of trade-based money laundering. We explore various public datasets that reveal insights about the gold smuggling chain and where financial institutions can look for signal in both public and internal data.

Whether cryptocurrency or precious metal smuggling, the role of data is critical. The ability to find actionable signal to make an impact is mission critical.

Sincerely,

Angel Swift

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