Anti-Money Laundering in a Nutshell

1. Front Matter

   Pages i-xiv

   PDF

2. What Is Money Laundering?

   • Kevin Sullivan

   Pages 1-13

3. Methods of Money Laundering

   • Kevin Sullivan

   Pages 15-35

4. Federal Regulations

   • Kevin Sullivan

   Pages 37-47

5. Building a Quality AML Program

   • Kevin Sullivan

   Pages 49-67

6. Know Your Customer and Customer Identification Program

   • Kevin Sullivan

   Pages 69-100

7. A SAR Is Born

   • Kevin Sullivan

   Pages 101-114

8. Tips for Law Enforcement and Financial Crimes Investigators

   • Kevin Sullivan

   Pages 115-135

9. International Standards

   • Kevin Sullivan

   Pages 137-150

10. Fraud and Anti-money Laundering

    • Kevin Sullivan

    Pages 151-158

11. Money-Laundering Red Flags

    • Kevin Sullivan

    Pages 159-169

12. Code of Federal Regulations Title 31 Section 103.18

    • Kevin Sullivan

    Pages 171-173

13. Glossary

    • Kevin Sullivan

    Pages 175-180

14. Back Matter

    Pages 181-186

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Anti–Money Laundering in a Nutshellis a concise, accessible, and practical guide to compliance with anti–money laundering law for financial professionals, corporate investigators, business managers, and all personnel of financial institutions who are required, under penalty of hefty fines, to get anti–money laundering training.

Money laundering is endemic. As much as 5 percent of global GDP ($3.6 trillion) is laundered by criminals each year. It’s no wonder that every financial institution in the United States—including banks, credit card companies, insurers, securities brokerages, private funds, and money service businesses—must comply with complex examination, training, and reporting requirements mandated by a welter of federal anti–money laundering (AML) laws. Ignorance of crime is no excuse before the law. Financial institutions and businesses that unknowingly serve as conduits for money laundering are no less liable to prosecution and fines than those that condone or abet it.

In Anti–Money Laundering in a Nutshell: Awareness and Compliance for Financial Personnel and Business Managers, Kevin Sullivan draws on a distinguished career as an AML agent and consultant to teach personnel in financial institutions what money laundering is, who does it, how they do it, how to prevent it, how to detect it, and how to report it in compliance with federal law. He traces the dynamic interplay among employees, regulatory examiners, compliance officers, fraud and forensic accountants and technologists, criminal investigators, and prosecutors in following up on reports, catching launderers, and protecting the integrity and reputations of financial institutions and businesses. In particular, corporate investigators will gain rich insights winnowed from the author's experiences as a New York State and federal investigator.

Kevin Sullivan is the director of the Anti–Money Laundering (AML) Training Academy, which provides AML, BSA, and compliance training, AML consulting, and AML independent reviews. He was the New York State money laundering investigations coordinator of the Immigration and Customs Enforcement (ICE) El Dorado Federal Task Force (NY/NJ HIFCA) in Manhattan. Sullivan’s responsibilities included case reverse-engineering, SAR review and analysis, and special projects developing intelligence on emerging money-laundering threats, trends, and patterns. He was first exposed to money laundering while a New York State Police investigator on an undercover narcotics detail. He was subsequently detailed to a money laundering and financial crimes unit of the FBI White Collar Crimes Task Force. Sullivan was a lead instructor for ICE’s Operation Cornerstone, which assisted financial institutions with their AML and BSA compliance programs and provided a liaison between private financial institutions and law enforcement. Sullivan holds a master’s degree in economic crime management from Utica College of Syracuse University and a certificate in executive management from Cornell University. He is a Certified Anti–Money Laundering Specialist, a founding member and past president of the NY Chapter of the Association of Certified Anti–Money Laundering Specialists (ACAMS), the Chairman of the ACAMS Education Task Force, and a member of the Association of Certified Fraud Experts. He is an adjunct professor at Utica College, an ACAMS instructor, a frequent speaker on AML at seminars, conferences, and webinars, and an expert commentator on money laundering in national magazines and television.