opinion writing lesson article
The enemy is the money launderer, and this is where we need … So be bold; endeavor to be accurate; and do make reference to characteristics and features which fuel your suspicion. Opinion Writing PowerPoint – Day Two Opinion Writing Prompt Review Writing Prompt. If you are unable to find a Website for a corporate customer with a busy account, say so. By way of example, it is always difficult to know the exact criminal origins of money flowing out of Russia, but at a minimum, there is likely to be some form of tax evasion.
In this week’s “Nailed It or Failed It,” we take down EY and JPMorgan Chase for apparently ignoring whistleblowers and give the SEC a nod for rewarding them. ‘FinCEN Files’ highlight bank leadership flaws, not compliance flaws, EY allegedly flubbed Wirecard dealings worse than we thought, Progress on beneficial ownership key to AML fight. The leaks were illegal; nonetheless, they are now in the public domain. The damning revelations from the “FinCEN Files” leaks have once again put Europe and its supposed world-leading anti-money laundering rules under the spotlight. Some will read the redacted narratives and ponder: what does it all mean, and what did the authorities do with the information? This is a high interest topic in our area right now. The key word is suspicion; more pointedly, suspicion of a crime. Then they'll do an easy writing exercise.
In the event you determine to allege another crime, such as drug trafficking, ask yourself how you have made and can later justify such a determination. In this lesson, your students learn how to establish themselves as authorities on their chosen writing topics. Thus, if we are uncertain, we should seek to find some certainty, even if this means talking to the customer, or more likely having the relationship manager talk to the customer. This will expedite the AML process by ensuring the SAR is quickly routed to the same regulator.
These were bold and direct assertions. Thankfully, they have all been carefully redacted prior to being shown in any broadcasts or publications, and the names of no bank employees have been exposed. Connect with us to join the compliance conversation. The 20,000-word report includes exclusive interviews, detailed graphics, photos, videos, and more. Having seen some of the SARs, I was struck by what was written, and in some cases I determined a SAR should not have been filed. Due to COVID-19, we will be holding the 8th Annual Compliance Week Europe conference virtually this year on 11 November. Compliance has been taking some heat in the wake of the “FinCEN Files” reports, but it’s banks’ senior leadership that failed, not the folks filing all those SARs.
We asked nine prominent chief compliance officers to look into their crystal balls, and all of them saw data and advanced technology playing a larger role in the future of the profession. Whereas fraud is a crime, layering and round-tripping are not. Understand what words mean. Moreover, it is important to ensure we use the correct words in the right way when drafting a SAR. As it appears, there are too many SARs to allow authorities to properly investigate the suspicions/allegations articulated in each one. Often, less is more when writing a SAR, thereby facilitating the accurate, expedient, and succinct delivery of important financial crime intelligence while simultaneously protecting the author from unwanted and unjustified scrutiny at some time in the future. In some instances, the reports have focused upon the actions taken by banks after the submission of the SARs. Jan 22, 2015 - Your students will learn the difference between opinion versus persuasion with this fun infographic about dogs. Opinion writers need to establish credibility so that their audience will value their opinion. Try to adhere to the facts, numbers, names, and addresses without expressing emotions or colorful opinions. He now applies his experience to the analysis and subsequent commentary of current compliance investigations and settlements. In a famous case in the United Kingdom, Shah v HSBC, the person completing the SAR stated he was not aware of the origins of the funds, but lack of awareness is not necessarily a basis for suspicion. It’s all about the wording, and to some extent the investigation of the activity which gave rise to the SAR.
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