Dear AML Community,
As a substack subscriber I am offering a FREE "Detailed Guide to KYC/CDD."
This guide will walk you through the crucial process of Customer Due Diligence (CDD), covering everything you need to know about collecting and verifying customer information - whether you're dealing with individuals, legal entities, trusts, or NPOs.
The guide will only be available to new and existing Substack subscribers until February 28th, 2025.
Important Note: This guide is not a substitute for your national AML requirements or internal procedures. However, it's designed to enhance your CDD capabilities and ensure you're effectively mitigating risks.
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These are the main news we found interesting for this week:
Block, Inc. has been fined $80 million by state regulators in Arkansas, California, Massachusetts, Florida, Maine, Texas, and Washington for violations of the Bank Secrecy Act (BSA) and anti-money laundering (AML) laws. Investigations revealed deficiencies in customer due diligence, suspicious activity reporting, and controls for high-risk accounts, creating risks of misuse for money laundering and terrorism financing. As part of the settlement, Block will engage an independent consultant to review its BSA/AML program and address deficiencies within 12 months.
BitMEX was fined $100 million for willfully violating U.S. anti-money laundering (AML) laws. The platform only required users to provide an email address, failing to implement proper know-your-customer (KYC) measures. Although BitMEX was prohibited from offering services to U.S. clients without an adequate AML program, its controls to prevent U.S. access were either ineffective or deliberately bypassed, allowing U.S. traders to use the platform. Senior executives knowingly allowed this activity to continue. Furthermore, BitMEX lied to banks about the nature of its operations, enabling it to process millions of dollars through the U.S. financial system without compliance.
Nigerian national Okezie Bonaventure Ogbata pleaded guilty to operating a transnational inheritance fraud scheme that defrauded over 400 U.S. victims, stealing more than $6 million. The fraudsters sent personalized letters falsely claiming recipients were entitled to multimillion-dollar inheritances but required upfront payments for delivery fees, taxes, or government clearance. Victims' funds were funneled through a network of former victims in the U.S., who were manipulated into forwarding money. No inheritance was ever paid, and the scheme targeted primarily elderly and vulnerable individuals.
American Express has agreed to pay $230 million to settle U.S. criminal and civil investigations into deceptive practices targeting small business customers. From 2014 to 2017, Amex misrepresented card rewards, fees, and credit checks while submitting false financial data for applicants. Between 2018 and 2021, it falsely marketed wire transfer products, Payroll Rewards and Premium Wire, with misleading claims about tax benefits. Additionally, sales staff used “dummy” employer identification numbers, such as "123456788," to bypass requirements for issuing small business credit cards.
In case you missed these posts:
Monday 13th January: What is Human Trafficking? (2 min read)
Tuesday 14th January: Only take risks you can accept (1 min read)
Wednesday 15th January: 10 Specific KYC/CDD Mistakes Companies Make and Can Prove Costly (1 min read)
Thursday 16th January: Where should you start with AML compliance? (1 min read)
Friday 17th January: What to really expect from LinkedIn – the brutal truth! (1 min read)
And if you are a compliance officer in Cyprus, join me for an evening of networking and discussion. The event is sponsored by Binderr. Register here.
That's all for this week! Wishing you great weekend!
Wondering who we are? AML Cube and its associates can assist you with:
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Don't hesitate to schedule a call with our team to discuss how we can help.
Best regards,
Anna Stylianou