Financial Crime

Updated FinCEN Final Beneficial Ownership Reporting Rule

On September 29, FinCEN issued a final rule implementing the bipartisan Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting provisions. This rule will strengthen the integrity of the U.S. financial system by making it harder for illicit actors to use shell companies to launder their money or hide assets. The rule describes:
  • who must file a BOI report
  • what information must be reported, and
  • when a report is due
Specifically, the rule requires reporting companies to file reports with FinCEN that identify two categories of individuals: (1) the beneficial owners of the entity; and (2) the company applicants of the entity. According to FinCEN, the rule aims to minimize burdens on small businesses and other reporting companies but to help, FinCEN will develop compliance and guidance documents to assist reporting companies. Two other rules, covering access to the database and an update to the existing CDD rule, are still pending.

BAFT Launches Certificate in Advanced Cash Management

WASHINGTON — BAFT, the leading global financial services association for international transaction banking, today announced the launch of its new Certificate in Advanced Cash Management (CACM), which includes a series of nine courses designed for individuals seeking to learn more about payments and treasury management. The certificate is tailored to those interested in expanding their careers in transaction banking, who have three or more years of cash management experience or have already completed the Certificate in Introductory Transaction Banking.

CACM will provide an in-depth understanding of cash management tools, techniques and best practices needed to be successful in various cash management disciplines. Learners will gain a deep understanding of treasury management and its impact on the financial ecosystem. The courses will also cover topics like liquidity management, information reporting, foreign exchange, correspondent banking and innovation.

“As someone with more than 20 years of experience in cash management and treasury, I believe this is an essential certification for Treasury professionals at both banks and mid-to-large-sized companies,” said Deepa Sinha, Vice President of Payments and Financial Crime, BAFT. “Transaction banking is a complex business, and it takes demonstrated expertise to master it. This course can help professionals reach the next level.”  

The courses will be led by Barry Tooker, a recognized expert in wholesale banking who has been involved in payment operations and treasury services for global banks for more than 45 years.

The certificate courses will be available through BAFT’s Learning Management System and are expected to take 10 hours to complete. The final assessment will include 80 multiple choice questions and students must answer 80% correctly to pass and receive the certificate.

Click here for more information on the Certificate in Advanced Cash Management.

About BAFT

BAFT, the leading global financial services association for international transaction banking, helps bridge solutions across financial institutions, service providers and the regulatory community that promote sound financial practices enabling innovation, efficiency, and commercial growth. BAFT engages on a wide range of topics affecting transaction banking, including trade finance, payments, and compliance.

BAFT Media Contact:
Blair Bernstein
Senior Director, Public Relations
[email protected]
+1 (202) 663-5468

Follow Us: @BAFT

BAFT Comments to UNCITRAL on Guidelines for International Identity Management

At the end of April 2022, the United Nations Commission on International Trade Law (UNCITRAL) released their “Draft Model Law on the Use of Cross-border Recognition of Identity Management (IdM) and Trust Services“. BAFT received a Request for Comment, with a May 27, 2022 submission deadline.

BAFT Endorses UNCITRAL’s Efforts

The need for the establishment of the IdM cuts across numerous facets of international transaction banking including trade finance, supply chain finance, payments, and areas of compliance such as Know Your Customer (KYC) and Anti-Money Laundering (AML). The process of establishing standards in the universal acceptability of the IdM is also at the core of the digitization of trade initiatives. Accordingly, BAFT fully endorses UNCITRAL’s efforts in formulation of the Draft Model Law.

The Draft Model Law confirms that the international dimension is essential to the use of identity management and trust services and more generally, of electronic services. However, the text confirms that there are two obstacles: i) technical incompatibility leading to a lack of interoperability, and ii) legal obstacles to cross boarder recognition.

BAFT Advocates for GLEIF’s LEI

To provide direction on overcoming these two obstacles, BAFT advocates for the implementation of the work already done by the Global Legal Entity Identifier Foundation (GLEIF) in the establishment of the Legal Entity Identifier (LEI). The LEI is a global ISO 17442 standard that connects key reference information and enables clear and unique identification of legal entities.

Digital transformation in global transaction banking is capable of reducing costs, improving efficiency, better regulatory control with less risk and collaborative opportunities for stakeholders in the global economy. The LEI is the only global standard for legal identity identification which is why BAFT has endorsed its inclusion in the Draft Model Law.

Read the Full Comment Letter Here >

Balance Is Key: New BAFT VP Deepa Sinha on Payments and Fighting Financial Crime

Via Trade Finance Global (TFG)

In April 2022, BAFT named Deepa Sinha as its new Vice President of Payments and Financial Crime. TFG’s Deepesh Patel interviewed Sinha to learn what led her to the association, her view on fighting financial crime, and her insights into the progress made in the payments space.

About Deepa Sinha

Deepa Sinha has been in the finance and treasury space for more than 25 years now, in both corporate and bank settings, accumulating a perspective on what’s needed from both.

During that time, she has worked for large banks such as Capital One and been on the advisory councils for J.P. Morgan, Wells Fargo, Bank of America, and Citi.

She also spent some time working for large corporates like the Carlyle Group and Caliburn International (now Acuity International), as well as non-profits like AARP.

Much of her experience lies with the implementation of treasury management systems and enterprise resource planning systems integrations, leading internal IT and business teams, and working with various internal and external stakeholders to build consensus and accomplish objectives.

PATEL: What led you to join BAFT and head up payments and financial crime?

SINHA: BAFT is the organization that international banks active in transaction banking look to for industry best practices, solutions, advocacy, policymaking, and knowledge-sharing.

I have been in the finance and treasury space for more than 25 years now and BAFT will provide me with an opportunity to fill an advisory role to our members on not only what their clients are looking for, but what is developing in the space, and how it can affect them and their business.

As technology advances and various international policies and regulations evolve, BAFT offers the knowledge and capabilities in this space to be ahead of those evolutions and advancements.

That’s why I wanted to join BAFT.

Fraud and Financial Crime

PATEL: What has been the impact of the pandemic on financial crime?

SINHA: The pandemic has been a time for both challenges and opportunities, with regard to financial crime, and associated regulatory compliance.

If we look at the data behind financial crime patterns, there is an uptick in cybercrime, which corresponds to an increase in electronic commerce and payments. The efficiency of newer payment methods presents an opportunity and a challenge for banks, regulators, and organizations like BAFT to strengthen regulatory compliance.

There is much work to be done, but the incredible team at BAFT is positioned well and has the ability to work closely with our members, partners, and policymakers in continually striving for success in these areas. 

PATEL: The trade industry has suffered some serious fallbacks due to fraudsters and issues around money laundering. Do you expect to see this increase moving forwards?

SINHA: We see trade-based money laundering and fraud as two distinct problems that require different solutions.

In most instances, trade-based money laundering is separate from trade financing and takes advance of fragmentation in the value and payment chains. Banks alone cannot solve this – it requires collaboration with customs, shipping companies and other stakeholders. Banks are using artificial intelligence and other tools to get better at mitigating money laundering, but it remains a stubborn problem.

As payments get faster and more frictionless, the risk increases. Fraud, however, is heavily driven by paper-based processes and we are seeing improvements in mitigating fraud as technology solutions are increasingly implemented.

As digital identity becomes more widespread, and duplicate financing solutions gain more traction, fraud mitigation will improve even further. However, we know that criminals constantly find new ways to evade the law, so we have to remain diligent. 

PATEL: Although within the industry there is a general consensus that regulation, reporting on and fighting financial crime are important, it’s also time-consuming, costly, and potentially at the cost of serving smaller MSMEs. How do we tread the line?

SINHA: As in everything, balance is the key. In order to protect assets and interests, and prevent financial crime, regulations, compliance, and due diligence are quite necessary.

However, in finding that balance, we also want to make sure that those same regulations, compliance, and due diligence responsibilities are not overwhelming, especially for smaller and medium-sized companies.

There still has to be some collaborative work between banks and regulators to fine-tune the “risk-based approach” to compliance. BAFT is committed to working with our international banks to understand and lessen the challenges associated with compliance, and also working with regulators to advise how ineffective regulations pose a hindrance to conducting business and actually increase overall risk. 

Progress in the Payments Space

PATEL: Has the pandemic accelerated the need for FIs to speed up and innovate in the payments space (real-time 24-7-365)?

SINHA: Not only did the pandemic accelerate the need for financial institutions to speed up innovation in the payments space, but it also accelerated the deployment of innovative solutions and adoption by corporate clients. 

Across the board, the name of the game is digitization. How we interact with the world as a populace is primarily online now, from shopping to groceries to paying our bills and both the banks and the clients they serve have responded accordingly.

With the advent of real-time payments from customer to customer, now business to business and between businesses and their customers, we are seeing an acceleration of the real-time-payment revolution.

Various markets in Asia were early adopters followed by Europe, but we’ve seen an acceleration in Latin American and North America on the domestic level. The next major innovations will be in real-time cross border payments.

PATEL: Where is the payments space in terms of adopting best practices and standards?

SINHA: Some elements of best practices – such as straight-through rates, payment times, reporting, and digital deployment, offer competitive advantages, so firms are constantly driving towards what they believe is best practice.

At BAFT, we focus more on standards and best practices for functions that are common and necessary for a healthier ecosystem, such as interbank transactions and risk management.

In that regard, our members are very active in collaborating through our committees and working groups. The community is very engaged in driving towards new standards such as ISO 20022 and working with providers such as SWIFT and other payment service providers that offer technology solutions that improve on current practices.

The Road Ahead for BAFT

PATEL: What are your missions and objectives at BAFT over the coming months?

SINHA: First on my list, as well as an ongoing goal, is to be at the forefront of new payments capabilities as they develop, as well as the policies and regulations that guide them, and be able to disseminate that to our members as quickly as possible.

My goal is to assist our members in achieving optimum productivity by leveraging technology and industry best practices in operational efficiency.

I also want to entrench myself as a subject matter expert on the challenges that our members are facing in the area of financial crimes, policies and regulations that govern them, and how to tackle those challenges head-on, with new developments and solutions in technology to prevent financial crimes before they happen, and to solve for them when they do.

Premier of Montserrat to Attend Two US-Based Meetings

Montserrat Premier and Members of the Caribbean Association of Banks to Discuss Banking on Visit to the U.S. at the 2022 BAFT Global Annual Meeting.

MONTSERRAT/WASHINGTON – The Premier of Montserrat, Hon. Joseph E Farrell will be on overseas duty from April 23 to May 5, 2022 as he will be attending meetings in Miami and Washington, DC.

Premier Farrell, whose portfolio includes Tourism, will attend the Seatrade Cruise Global Conference in Miami Beach, Florida from Monday April 25 to Thursday April 28, 2022. His delegation will include the Director of Tourism, Rosetta West-Gerald; Project Manager at the Tourism Division, Charlesworth Phillip and Private Sector Representative, Tour Operator, Roselyn Cassell-Sealey.

In addition to their attendance at the conference which includes workshops, the Montserrat delegation will also attend meetings with several cruise liners and will have an opportunity to display Montserrat branded collateral during the Expo which runs from April 26 to 28. The Montserrat Port Development project will also be highlighted during the week long activities.

Following this meeting, the Premier & Minister of Finance will travel to Washington, DC for the May 1-4, 2022 BAFT Global Annual Meeting.

The meeting will provide an opportunity for the Caribbean Association of Banks (CAB) Member Banks to network with North American banks at the largest correspondent banking event in the United States where industry professionals will be able to network, conduct bilateral meetings, and engage in topical discussions and sessions on the global transaction banking industry.

There will also be a Caribbean Banking Roundtable hosted on May 2, 2022 where BAFT and CAB will convene a group of Caribbean and U.S. Banks along with respective governments together in one room to discuss challenges in correspondent banking for the Caribbean community and opportunities to engage with North American banks.

BAFT Media Contact:
Blair Bernstein
Director, Public Relations
[email protected]
+1 (202) 663-5468

Follow Us: @BAFT

BAFT Announces New Vice President of Payments and Financial Crime

BAFT has named Deepa Sinha as its new Vice President of Payments and Financial Crime. Sinha will lead the association’s payments, cash management and financial crime-focused policy initiatives.

WASHINGTON – BAFT, the leading global financial services association for international transaction banking, has named Deepa Sinha as its new Vice President of Payments and Financial Crime. Sinha will lead the association’s payments, cash management and financial crime-focused policy initiatives, as well as support its related councils and committees.

Sinha will work to advance the goals of the payments and cash management industry through standardization, defining best practices and developing usable industry data. She will also be responsible for formulating policy recommendations and educating industry stakeholders including practitioners, regulators, policymakers and the broader business community.

“I’m excited for Deepa to join BAFT,” said Tod Burwell, President & CEO, BAFT. “Her experience in corporate treasury and consulting roles provides her with a unique perspective on critical cash management and financial crime issues that affect our members. With the rapid pace of change in this space, her experience will be quite valuable in driving issues forward.”

Prior to joining BAFT, Sinha accumulated more than 25 years of treasury and cash management experience at both corporations and banks. She formerly served as Treasurer at Caliburn International, now Acuity International, where she oversaw cash forecasting, working capital and debt management, and implemented policies and banking technology to support all core treasury functions. As the Associate Vice President of Banking Operations and Relationships at the Carlyle Group, she developed the cash management, FX and banking platforms, and built and managed the infrastructure for multicurrency cash management across 5,000+ bank accounts at more than 100 global banks. She also served on both the JPMorgan Chase Treasury and Wells Fargo Treasury Advisory Councils. Sinha is a graduate of George Mason University where she received a bachelor’s degree in government and global systems management.

BAFT Media Contact:
Blair Bernstein
Director, Public Relations
[email protected]
+1 (202) 663-5468

Follow Us: @BAFT