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Blog: Cyber Security

Securities licensing confuses bankers for a structural reason: the licenses are organized around what a person may sell and who registers them, while bank job titles are organized around who the person serves. The mapping between the two is not obvious, and getting it wrong produces either an unnecessary exam or a violation.

This post sorts out which license a given bank role actually needs, what each one permits, and the requirement that surprises most candidates — ...

"RegTech" describes a market rather than a technology, and the market's marketing has converged on a single promise: software will make compliance cheaper and more reliable. Sometimes it does. The variable that decides is almost never the software.

This post takes a buyer's view. Our post on AI in compliance covers what machine learning specifically can and cannot do in AML and fraud ...

Instant payments differ from everything else in a bank's payment stack in one property that drives every other consequence: the funds are final when they arrive, and they arrive in seconds.

Not "available." Final. There is no settlement window in which to reconsider, no return reason code, no chargeback. A payment sent in error or induced by fraud can be recovered only if the receiving institution cooperates and the funds are still there. Every operational, fraud, ...

Most community bankers believe they have limited cloud exposure because the institution has not migrated anything. That belief is almost always wrong, and the reason is worth stating first: the bank's core processor, digital banking platform, monitoring system, and document repository are running on someone's cloud infrastructure. The institution's exposure is real, it is indirect, and it is largely invisible in a vendor file that describes the provider without naming what ...

Digital account opening is where a bank's compliance program and its growth objective collide most directly, and the collision is usually resolved badly in one direction or the other. Institutions either build a flow so cautious that most applicants abandon it, or accept a vendor's default configuration and open accounts on verification nobody has evaluated.

The resolvable version of the problem is narrower than it appears. The question is not how much friction to have. It is ...

Cybersecurity at a bank is a supervised obligation with a board-level accountability structure, not an IT budget line. Examiners assess it, the notification deadlines are measured in hours, and the largest exposures usually sit at third parties rather than inside the institution's own perimeter.

This covers the threats that actually produce losses, the regulatory framework, and what a defensible program looks like.

The Threats That Matter

Threat lists are easy to

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Identity theft reaches a bank in two very different forms, and conflating them produces controls that address neither well.

New account fraud uses a stolen or fabricated identity to open an account the real person never requested. The bank's exposure is credit loss and the mule risk of an account opened to receive proceeds.

Account takeover compromises an existing customer's access to an account they legitimately own. The bank's exposure is ...

The BSA/AML risk assessment is the document examiners open first, and the one most institutions treat as an annual formality. That mismatch explains a large share of program findings: the assessment says one thing, the controls do another, and nobody noticed because the assessment was written to be filed rather than to be used.

This is a working method for building one that actually drives the program.

What the Risk Assessment Is For

Its purpose is to identify the

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