Five questions with: Kristyn M. Glennon

Kristyn M. Glennon is the vice president, Banking Secrecy Act/Anti-Money Laundering officer at BayCoast Bank, a community bank headquartered in Swansea and serving southeastern Massachusetts and Rhode Island. Glennon is responsible for coordination and development of policies, procedures and monitoring programs for the bank and its affiliates to ensure day-to-day compliance with federal Bank Secrecy Act/Anti-Money Laundering regulations, including Office of Foreign Assets Control and the USA Patriot Act. Glennon received her bachelor’s degree in criminal justice from Stonehill College and her paralegal certificate from Quincy College. She has more than 20 years of banking experience.

PBN: What attracted you to your position at BayCoast Bank?

GLENNON: The new position at BayCoast Bank allows me to focus on two areas of interest, risk and [Bank Secrecy Act/Anti-Money Laundering]The position has at times placed me out of my comfort zone, which I think is not only important for personal growth, but also a motivational factor. This career choice brings a variety of challenges that are unique and forces you to think “outside the box” on a daily basis, as no situation is the same. In addition, this position allows me to work with individuals that I have met over the years through banking and have a tremendous amount of respect for.

PBN: Your college degree was in criminal justice, followed by paralegal training. Is this BSA/AML position an expression of a personal itch to be a crime fighter?

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GLENNON: I believe all three are more of a desire to help other people. My criminal justice degree and paralegal training allows me to work with both law enforcement and the court system on a variety of cases and issues. The opportunities enhanced my analytical skills and showed me that I had to think quickly and be disciplined to address a variety of challenges. The current BSA/AML position has allowed me to work with an amazing group of individuals who want to identify and report potential criminal activity, which in the end creates a positive impact on the communities served by the bank.   

PBN: From the point of view of a business owner or manager with normal banking relationships, why is banks’ compliance with the Bank Secrecy Act important?

 GLENNON: The Bank Secrecy Act requires U.S. financial institutions to assist U.S. government agencies in the detection and prevention of criminal activities, such as money laundering, drug trafficking, possible terrorist financing and other illicit activities. The BSA/AML regulatory environment and the financial services environment have gone through many changes over the years and continue to evolve. When the Bank Secrecy Act was enacted in 1970, the primary focus was to require financial institutions to maintain records the government could use for investigating crimes involving criminal activity and tax evasion. In 2001, the USA Patriot Act was passed, which changed the way the Anti-Money Laundering and the Bank Secrecy Act looked at financial crimes and transactions that were now conducted through a variety of channels. The USA Patriot Act criminalized terrorist financing and imposed a higher degree of customer identification requirements on financial institutions. Financial institutions are required to maintain a robust BSA/AML program, as we play an important role in protecting the country from those individuals who attempt to use the financial system to launder money associated with criminal activity, finance terrorism or other financial abuses. Business owners can aid in the fight against illegal activity by providing the bank with a detailed description of the nature and purpose of their business. This may also include information on expected transactional activity as well as information on the individuals or businesses they interact with. Providing this information will allow the bank to develop an awareness of the business and the types, thresholds and frequency of transactions the business is likely to engage in. By substantiating expected activity, financial institutions can better focus on identifying and reporting inconsistent or suspicious activity that may be occurring in order to evade financial measures designed to combat terrorism and other threats to our security.

PBN: Why is it important for the banking world to fight money laundering? What consequences does this crime carry for the rest of us?

GLENNON: Money laundering is the practice of taking what is known as “dirty” money and making the funds appear clean. In addition, it can be used to disguise the true source, ownership and/or use of funds. Money laundering involves three steps: placement of funds into the financial system; layering the funds through various financial transactions; and integration to create the appearance of “clean” money through the purchase of assets. Maintaining a strong due diligence program is the most effective tool a bank can have to fight those who are attempting to launder funds or support terrorist activity. Financial institutions who know their customers, require appropriate identification/documentation, and monitor for unusual or suspicious activity are assisting law enforcement in the prevention of this illegal activity. Money laundering disguises illicit activity and makes it profitable for criminals. By working together, financial institutions and law enforcement can identify the activity and protect the nation on both an economic and security front.

PBN: How can businesses play a role in preventing money laundering?

GLENNON: Businesses can also play a role in preventing money laundering. When dealing with their customers, they should think about the following:

  • Do I know this customer? Was the individual referred by a reliable source or did they contact them from an unknown origin? Similar to a bank, do your due diligence on the individual or business.
  • Do I really understand the nature of the business? What are they doing? Where does their money derive from?
  • Am I comfortable with what the individual is asking me to do? Does it make sense?
  • Always ask for documentation – there is never too much paper.
  • Be mindful of unsolicited emails or the links within them.