barbarakeller

/Barbara Keller

About Barbara Keller

Barbara I. Keller, CAMS, CFCS, is currently an independent consultant. For the last four years of her federal career, she was FinCEN’s deputy associate director for compliance and enforcement.

OCC Clarifies Its Expectations in Updated Guidance for Handling Third-Party Relationships – An Alacra Compliance Primer

In October 2013, the Office of the Comptroller of the Currency (OCC), the U.S. regulator of national banks, issued Bulletin 2013-29–guidance for assessing and managing risks associated with third-party relationships. The OCC defines a third-party relationship as “any business arrangement between a bank and another entity, by contract or otherwise.”[1] This bulletin […]

Enforcement Actions for U.S. Sanctions Violations Offer Lessons for Compliance – a new Alacra Compliance Primer

Barbara Keller, CAMS, CFCS, and former Deputy Associate Director for Compliance and Enforcement for FinCEN, has written a new Alacra Compliance Primer which details the evolution of several of the most significant cases of U.S. sanctions violation cases, some of which also included penalties for AML violations. Recent actions have been taken primarily against foreign banks […]

Alacra Compliance Primer – Enforcement Actions for U.S. Sanctions Violations Offer Lessons for Compliance

Barbara Keller, CAMS, CFCS, and former Deputy Associate Director for Compliance and Enforcement for FinCEN, has written a new Alacra Compliance Primer which details the evolution of several of the most significant cases of U.S. sanctions violation cases, some of which also included penalties for AML violations. Recent actions have been taken primarily against foreign […]

Alacra Compliance Primer – Positive Developments on Beneficial Ownership

It is widely accepted that illicit actors continue to create legal entities, masking beneficial ownership information in order to facilitate access to the financial system and conduct financial crimes. A number of developments have recently occurred that may help the United States make progress on requiring the identification of beneficial ownership of businesses and accountholders… […]

Positive Developments on Beneficial Ownership

It is widely accepted that illicit actors continue to create legal entities, masking beneficial ownership information in order to facilitate access to the financial system and conduct financial crimes. A number of developments have recently occurred that may help the United States make progress on requiring the identification of beneficial ownership of businesses […]