The FinTech space continues to proliferate — creating new markets for the payment and wallet needs of the masses. Leveraging technology to put the control of money movement into the hands of the masses breaks all of the conventional norms of banking — hence the disruption and revolution we have been seeing over the past decade.

With most successful revolutions comes the shock of becoming the trusted and governing body of the people that decided to follow you to the better place or way. In the FinTech revolution — many scaling and successful platforms have had to learn this lesson…


Here’s a short guide for not “writing” your bank into policy traps with audit and exam teams. Let’s start with the title of this story — notice it reads Policy vs. Policies. Most of the organizations that I have been inside of overthink the written (documented) aspects of an effective Anti-Money Laundering (AML) program — the policies for everything and anything approach.

An alternative framework can breakdown policy vs. standards vs. procedures.

AML Policy

This is a statement — a statement that articulates the Board of Director’s and Management’s position on intent. Articulated intent should be precisely mapped to two (2) aspects…


The relative aggregate amount or number — a definition of size. When applied to the money laundering problem we most often gravitate to the very dated UNODC estimate (an aggregate amount given in a range on an annualized basis). The accuracy of the estimate is problematic for a number of reasons — it’s stale; it’s unreliable; and it’s narrowly constructed.

Viewing the money laundering problem quantitatively is innate — we live in a time when quantitative data derived from scientific and mathematical methods are golden to decision cycles. What we miss in this view — is the fact that the…


If you’re in the financial services industry you should be painfully familiar with the KYC acronym (short for Know Your Customer) — an industry coined term with origins dating back to the USA PATRIOT Act and its Customer Identification Program (CIP) provision.

Like most components of the AML (Anti-Money Laundering) universe — KYC tends to get more complicated than it really needs to be. This story will aim at outlining the simplicity of the measure aimed at simply knowing who your organization is doing business with.

Yes that is the basic intent of every law and/or regulation falling under the…


The digital age of channeling content at speed and scale continues to expand. Fast paced innovation from Facebook, Twitter, YouTube, and the like — affords individuals, groups, organizations, institutions, governments, and networks to release both impulsive and highly strategic coordinated content into the public domain. While most content is without harmful intent, some content carries deliberate danger and consequential impact. One could also argue that all content comes with an intentional effort to create a narrative or deliver a singular message.

As we have recently witnessed with issues like social justice, election integrity, and other issues of public interest —…


Originally published on LinkedIn August 7, 2019

In a space where credibility is often inherent to those who are constantly on the main stage — I wanted to take the time to recognize what I believe to be a new wave of game changers, courageous leaders, dedicated practitioners. These professionals are innovating and making real change for the better.

Give the mic to these five rising stars:

Joseph Gillespie

Founder and President at riskCanvas, a GENPACT company

Joe and his team have brought their experience as analytical and tech enabled war fighters from the DoD and IC to industry to change the…


Originally published on LinkedIn April 4, 2019

We are an early-stage data and technology company. Our primary focus is innovating in order to yield data products and technology platforms that create better impact and more efficiency for our customers. So, it only made sense for us to make our own investments in a tech ecosystem that makes our work more efficient and keeps us focused on innovating.

When you think of technology solutions you often associate them with cost and learning hurdles within organizations of any size, but even more so larger organizations. Whether it is a budget restricted environment…


Originally published on LinkedIn October 20, 2017

We are all fascinated with the prospects of advanced technologies within the financial crimes risk and compliance space. Advanced technologies are key to enabling optimal performance across all facets (governance, programmatic, and operational) of a financial crimes risk and compliance program. Whether it be the tool for collecting and exploiting external and/or internal enterprise data (e.g., metrics — KRI), or enabling workflow (e.g., analysis, investigation, reporting, etc.), or the mechanism for extracting data derived from workflow (e.g., …


Originally published on LinkedIn April 14, 2016

There is a reason why the United States Government (USG) has an Intelligence Community (IC) comprised of 16 members, an enormous budget, and federated/integration leadership in the Office of the Director of National Intelligence (ODNI). That reason is simple — intelligence is important! At the heart of critical decision-making processes is information. The best type of information is sourced, validated, analyzed, exploited, and synthesized into consumable intelligence. At the national level, intelligence helps shape policies and actions across economic, foreign relations, defense, security, and criminal justice issues.

How in the world does the aforementioned have anything to do with a Financial Crimes Program in the private sector?

The answer is simple — intelligence…


Originally published on LinkedIn April 8, 2016

There may seem like no greater challenge than building a sustainable financial crimes program within a financial institution. With polarizing forces at play, building a program that supports national security and law enforcement missions while simultaneously supporting the growth and profitability of the financial institution is a daunting task. Having been in the trenches at multiple financial institutions over the past decade, the one common thread I have seen time and time again is the narrow or tactical approach to the challenge. Simply stated, financial institutions often overlook the value of comprehensive strategy…

Vic Maculaitis

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