Take Home Compliance

Whenever possible, Money Compliance has been trying to provide some job posts from LinkedIn in a post called Jobs in Compliance. As the blog transitions over from everyday to twice per week this fall, the Friday edition will be expanded. Jobs in Compliance will be a segment of the Friday post called Take Home Compliance. On Mondays or Tuesdays, there will be a post that will address specific compliance issues. If it hasn’t been clear, the transition of this blog will be from news (like JD Supra and FCPA Blog) and high level advice (like Michael Volkov and Richard Bistrong) to more nitty gritty. The idea is this: readers have multiple sources for news. “Experts” in the field who give advice and have exposure tend to focus on things that really aren’t very specific to compliance. Their advice could be about corporate culture in general. And while corporate culture is the best way to prevent running afoul of the law, there are lots of things that culture just cannot tackle that are really specific to the functions in the compliance department. This blog will try to provide that function specific information and advice. Also mentioned previously will be a greater effort to expand the resources page. Please look out for that in the future.

So, here’s the first entry of Take Home Compliance:

A cryptocurrency mining firm HashingSpace has filed with FinCEN as a MSB. The best known cryptocurrency is BitCoin. Money Service Business is a legal designation for non-bank financial transaction companies, not including credit cards. Western Union is the best known MSB. FinCEN is the abbreviation for Financial Crimes Enforcement Network, the division of the US Treasury that deals with the deterrence, prevention, and investigation of financial crimes outside of the capital markets. This is move to make BitCoin more accepted. BitCoin has taken a dive in the last year. A year ago it was valued above $500 per coin and now it is a little above $225, losing more than 50% of its value. The current problem with BitCoin is that it is being used as an investment rather than a vehicle for transactions. Nikhil Gupta at NewsBTC

DOJ has created a position for compliance counsel. The idea is to differentiate between effective compliance and paper compliance. Compliance with the law on a point by point basis by missing the purpose of the law is paper compliance. Common sense would lead one to believe that those in paper compliance will be prosecuted more harshly than those in effective compliance who may not meet the letter of the law because the whole point of compliance is to deter and prevent incompliance. Alison Tanchyk and Margaret Erin Rodgers at Daily Business Review

CFPB focuses on the little know Reverse Mortgages. A reverse mortgage is a unique type of loan for homeowners age 62 and older. This special type of loan is frequently insured by the Federal Housing Administration and allows homeowners to access the equity in their homes, without making monthly mortgage payments. Borrowers are not required to repay the reverse mortgage loan as long as they live in the home. However, the loan must be repaid when the last surviving borrower dies, moves out, or sells.” – Montoya M. Ho-Sang at Banking Exchange

Financial Regulator Compliance has become a boon for the people who might be working against the economy? That’s the perspective that is pushed in a Bloomberg article about JPMorgan has hired 8,000 people in compliance and controls. Supposedly even non-financial firms are hiring compliance officers to develop ethical policies to entice Millennials to join them. Even headhunters are focusing on compliance, some ditching other types of recruitment altogether. Anthony Effinger at BloombergBusiness

“Neither banks nor regulators emphasize regulatory excellence the way that they should.” That’s “why banks have trouble getting compliance right.” Kathryn L. Farrell at American Banker

From The Blog

Two compliance lessons from the Ashley Madison scandal: HERE and HERE.

Jobs in Compliance


What particular compliance requirement is making your life difficult these days?


Marcus Maltempo is a compliance professional with more than a decade of experience helping banks, law firms and clients manage investigations and regulatory responses. He is a member of ACAMS and ACFE. 

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