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Frank's blog archive

2022 (11)
Frank Cummings

Frank Cummings

CEO at AML Partners LLC
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The Legitimacy Life-Cycle – All Risk Mitigated

28 Oct 2022

The Legitimacy Life-Cycle – All Behavioral Risk Mitigated Lifecycle management has become an AML Compliance buzzword. But it’s often just new wrapping on the same old package. The Legitimacy Lifecycle, in sharp contrast, looks at the lifecycle challenge with a comprehensive emphasis on Risk relevance and Risk mitigation. Unlike other lifecycle-mana...


Hosted Managed Services for KYC/AML, really?

12 Sep 2022

Hosted Managed Services--A crucial option for institutions striving to maximize RegTech capabilities, focus on core business Custom fit. Tailored. Bespoke. Made to order. If you’ve been tracking trends in RegTech and GRC solutions, you might recognize how those terms describe an innovative new direction: hosted managed services. Prior to the pande...


What AML rules should I run

06 Sep 2022

That’s the question I get asked most often by AML Compliance colleagues--and it’s the question that worries me the most. That question tells me that the financial institution likely has a major problem with its Risk-based Approach. I’ve been doing AML for close to 20 years now, the first seven implementing “other people’s software” or just Ops wo...


I Am Not a Boss or a Leader; I Am an Enabler

23 Aug 2022

I Am Not a Boss or a Leader; I Am an Enabler I have been around the block far more times than I would like to count. I have been led, and I have led. And I have come to realize that neither will make you truly successful. Leading organizations large or small does not mean you are successful. It means you played the game well enough to be allowed to...