It’s a whole new decade. Change is in the air. Reform too is in the air, and as always, BANKS are at the heart of it. With all the talk of reform and intensified scrutiny, however, the threat of money laundering and non-compliance with the Bank Secrecy Act remains at the top of the list. Regulatory reform means changes to many requirements, including those associated with BSA and OFAC, and there is no let-up for enforcement in sight. With new products, new access to the banking system and emerging payment alternatives, the challenge to BSA/AML compliance has never been greater. Bank security, fraud, red flags, and product vulnerability have seen a convergence with BSA/AML/SAR programs and investigations. There is even an obligation to prevent unlawful internet gambling (no joke!). In today’s difficult environment, with increased penalties and enforcement alongside reduced budgets and resources, the need for quality education and training has become even more critical. The goal is to do more with less, while dealing with the evolving threats to your compliance program and to your institution.
- How does your institution keep up with changes – to regulation and technology?
- How do you manage for success?
- What lessons are there to be learned from recent exams and enforcement?
- How would you identity and weigh the impact and key aspects of getting the job done in a difficult and unpredictable economic environment?
Answers to these and other questions will be found at the 2010 BSA & AML School – a forum for educational information-sharing and hands-on deliberation. For almost 25 years, NABS/Profit Protection has developed and conducted seminars, workshops, conferences, and schools throughout the U.S. on security, fraud, and BSA/anti-money laundering. This program consistently delivers, and has become the PREMIER BSA/AML educational event and once again brings together a diverse offering of topics, solutions, and value-added benefits.
In today’s challenging environment, today’s BSA/AML professional demands...
- Hands-on, real-time, intensive focus and in-depth knowledge of today’s rules and regulations
- The ability to optimize allocation of limited resources to meet those challenges.
- A means of meeting the expectations and exam scrutiny as a “qualified” BSA/AML executive
- Appropriate management and operations skills beyond mere knowledge of laws and regulations
- BSA examination survival skills – asking much more from the BSA program than ever before
- Insights into the risk-based interagency exam along with implementation strategies
- Recognition that community banking is vastly different from regional, superregional, and multi-national banking
- Understanding that practices to know the customer and know
Based on comments and feedback from previous evaluations, this year’s program takes a new and in-depth look at several areas. These topics reflect the emergence of new or heightened areas of risk and industry efforts to meet those challenges:
- The convergence of financial fraud and money laundering
- 2010 Exam Manual — New areas of focus
- Evolving product, payment and person risks
- Effective tips on meaningful training – from the front line to the boardroom
- Identifying key aspects of regulatory and reputation risk
- Managing compliance with the realities of a challenging economy
- No surprises! Your bank’s board of directors, management, and stakeholders expect full compliance, and your auditors and examiners expect no less!
- Sessions that cover every aspect of BSA and money laundering compliance! “BSA/AML Challenges: Bridge to the Past — Preparing for the Future”, looks at the nuances and enforcement of banking reform, new law and regulation, along with how today’s compliance professionals deal with these changes. Includes shared knowledge and critical idea exchange.
- Meet the rapidly changing demands of compliance! The pace of change has never been more rapid, and the expectations have never been higher. This program continues to meet and exceed all expectations year after year.
- Extensive, practical, hands-on knowledge! For almost 25 years, NABS/ Profit Protection has developed and conducted educational programs on BSA and AML throughout the country, reflecting the insight and experience of practicing, banking professionals.
- Value added benefits! More bang for the buck – without leaving the state! The Annual BSA & AML School will again feature an unparalleled group of speakers and topics – bringing insight and experience to help understand how these changes will affect bankers at the bottom line. For banks closely watching the bottom line, this program is still the best value around. Consider that participation in this program is NOT an expense to the bottom line; rather, it’s an INVESTMENT that will pay huge dividends!
- Experienced faculty discussing issues in an engaging and thoughtful environment
- Discussion, regulatory requirements and step by-step guidance on new and emerging BSA/AML matters
- Cases and practical tips on developing and refining management skills to deal with AML challenges
- “Credentials” from an academic approach – shared knowledge and valuable “take aways”
- The perspective, skill-set, tools, and understanding to help deal with issues
- A unique opportunity for peer exchange and interactive discussion
- Real life solutions and “best practices” for meaningful program management
- Valuable networking opportunities
- Value-added benefits, including how to:
- Build, maintain, and refine an effective riskbased BSA/AML Program
- Research and find answers to everything from fundamentals to technical questions
- Recognize and respond to telltale signs and red flag indicators
- Analyze and resolve issues relating to your bank’s program
- Identify and weigh the risks relating to money laundering
- Survive the intensified exam environment
- BSA and AML specialists - from experienced veterans to new recruits
- Compliance, legal, audit and support staff
- Operations specials
- Trainers and supervisors
- Internal control specialists
- Bank security and risk managers
- Business unit and front-line supervisors, including trust, lending, private banking, and corporate risk
- Consultants
- Security and fraud specialists/investigators
- Members of audit, BSA and compliance committees
- Serious professionals with banking background looking for “in-depth” knowledge and articulation of the issues
In these challenging times, this opening session will set the tone for the school and help students plan and allocate resources for 2010. It will include considerations and updates on legislative and regulatory initiatives, as well as the meaning of enforcement actions and an updated exam manual. It will highlight what to watch for, and how these impact points could affect internal controls and continue to meet future regulatory expectations and avoid problems with law enforcement.
This session highlights the stages of traditional and “reverse” money laundering (terrorist financing), along with the banker’s role in identifying and combating them. Discussion will include cases involving key elements of the process by which attempts are made to disguise or conceal the true source, origin, ownership or control of the funds.
With the introduction and popularity of new products and payment channels, as well as bank customers who offer and utilize these channels, the challenge is to identify the risks and vulnerabilities associated with fraud and money laundering. From e-payments to mobile banking to stored value instruments, this session will help to evaluate the institution’s risks and mitigating internal controls associated with these products, payments, and persons, along with standards in new areas of risk
- ACH transactions
- Stored Value Cards/Electronic Cash
- Remotely created checks and remote deposit capture
- Third party payment systems
- PEPs, VIPs, and Political Figures
- NGOs & Charities
- Impact on payments — the “Unlawful Internet Gambling Enforcement Act”
Banks continue to be on the front line and are subject to rigorous scrutiny for compliance with OFAC sanctions. Updated exam guidance, recent enforcement actions, and regulatory expectations will be discussed, along with the impact of technology on the OFAC program.
There were significant revisions recently to the CTR process as well as the exemption rules that took effect in 2009. The session will address recent CTR rulings and exam issues, along with changes to the exemption process. The changes affect the need to file designation forms, the biennial renewal process and required timeframes. This session considers the changes in light of a review of the exemption process. A brief reminder of reporting and recordkeeping rules will also be addressed, including Section 314, funds transfers, the $3,000 rule, and general standards for reports and records created, retained, and retrieved by banks.
Regulatory guidelines require banks to develop procedures to detect identity theft through the use of red flags and suggest that this can be accomplished through a bank’s CIP procedures. The two rules, however, present some inconsistencies. In addition, there have been red flags established for money laundering and OFAC violations for years. This session will address the extent to which your various programs may satisfy these varied needs, and how to establish priorities for action.
- Money laundering red flags
- ID theft red flags and risk-based customer identification
- OFAC red flags
Even though the surge in mortgage fraud may be behind us, there are still areas of exposure – from foreclosure and credit counseling scams to laundering through commercial real estate. What will be the next wave of financial crime to take its place? The challenges for bankers are immense – especially given the state of the economy, higher risks, and access to international markets. This session will explore some critical points of impact from BSA, AML, and OFAC, along with a look at recent cases of fraud and related financial crimes affecting the lending function. The discussion will include analysis of recent cases and telltale signs, along with some specific action items to minimize exposure to money laundering and financial crime.
One of the most significant developments in 2009 was the discovery of cases of financial fraud and offshore tax evasion worth billions. This session will analyze some recent cases of fraud and money laundering, and consider what went wrong. It will also consider the role that banks can play in early detection of fraud by using existing AML systems and improving both IT and internal communications. This will demonstrate by example what banks can do and what regulators may expect.
The bank’s risk assessment should help identify strengths and weaknesses in the BSA/ AML and OFAC programs and help prioritize bank efforts. As a dynamic process, it also provides an integral link with customer due diligence and ongoing activity monitoring. The BSA/AML exam manual provides that procedures should allow the bank to differentiate between lower and higher risk customers at the time of account opening. Consider this in the context of specific high-risk categories such as MSBs, attorneys and PEPs. This session will focus on current technology and program expectations, and will discuss refining the risk assessment and identifying the need for enhancements to the BSA/AML and OFAC programs.
The risk-assessment may evaluate a business as a high risk MSB. This case study representation will consider what should be used to make such determination and what, if any, steps are warranted toward enhanced due diligence.
The bar has been raised. Expectations have never been greater. This discussion
identifies the tools needed to both develop and implement a strong SAR monitoring
system, as well as to report effectively on suspicious activity. Inadequate monitoring
and reporting have been the focus of recent enforcement actions.
Identifying suspicious activity is at the core of banks’ responsibilities to FinCEN and financial regulators. This session will help identify the emerging issues surrounding the monitoring, detection, and reporting of suspicious activity, including limitations of SAR sharing and the challenges this presents.
How has the industry met the mandates of the Bank Secrecy and USA PATRIOT Act relating to the internal compliance program? The discussion considers common exam deficiencies relating to BSA programs, policies and procedures. Each institution must have a formal, Board-approved program that is appropriate to its risk profile and that considers the existing system based on industry trends and practices. There is very little guidance, however, about how detailed that should be and whether it meets individual examiner expectations. This presentation explains a methodology for identifying what issues your policy should address and how to articulate them, including the “five P’s of BSA compliance” and the “five R’s of combating money laundering”. This session will review basic program requirements with consideration to today’s technology and environment, together with increasing expectations from the exam front.
One of the most common, yet most avoidable, violations is that of ineffective training. This session will consider a variety of methodologies and offer tips for improving the development and delivery of BSA/AML training – from the front line to the boardroom.
Even more unnerving to most banks than law enforcement action is the prospect of a bad audit or exam. This session will evaluate the impact of change and reform in light of effective BSA/AML/OFAC compliance programs. This session will discuss several alarming trends in the inadequacies of effective internal controls, independent testing, risk assessments, and monitoring systems, among others. It will offer valuable and practical tips to help prepare for and work through your next BSA/AML and OFAC examination, including some insights into best practices and worst-case scenarios and enforcement actions..
Participants are required to make their own reservations. The seminar hotel is The Wynfrey which is located in Birmingham. The room rate is $148 for a single or double room. Please reference The Alabama Bankers Association room block to get the group rate. To make reservations, call The Wynfrey at (205) 987-1600 or (800) 996-3739. The cut off date for room reservations is November 3. After November 3, reservations will be accepted on a space available basis.
Dress for the seminar is business casual. To ensure your comfort, please bring a jacket or sweater as we cannot always control the temperature of the meeting rooms. If you need additional information, contact The Association office at (334) 834-1890 or by email at info@alabamabankers.org.
Fees include instruction, materials, lunch and refreshments. No written confirmation of seminar registration will be sent from the ABA. Full registration will be refunded if a cancellation is received on or before ten days prior to the meeting. No refunds will be given for cancellations after December 1. Substitutions are welcome. All cancellations and substitutions must be received in writing.
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Before Nov. 1 |
After Nov. 1 |
After Dec. 1 |
| Member |
$525 |
$575 |
$625 |
| Nonmember |
$825 |
$875 |
$925 |
Phillips G. Gay, Jr., CAMS, CRCM and CRP, is the principal of the Compliance Advisory Service, Coral Springs, FL, and is a frequent speaker at state and national compliance programs, and senior advisor to a national compliance training concern. He was a former Senior Vice President of a community bank and former Vice President of regulatory compliance for First Union Corporation (now Wachovia) and a Senior Vice President for Bank of North America. Gay has served in an advisory capacity on numerous government and American Bankers Association (ABA) committees dealing with regulatory compliance matters.
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