Damage Control: Essential Post-Crisis Procedures to Minimize Fallout
The last thing a compliance department wants is to receive regulatory criticism after an examination, or worse yet an enforcement action. However, if this does occur at your institution, the best thing is to turn the situation into a positive experience by learning from your mistakes. In fact, not doing so could be the deciding factor between a cease and desist order or a multi-million dollar penalty. For example, in the case of Riggs Bank, the same AML deficiencies were identified repeatedly since 1997. Nevertheless, it was not until 2004 that the bank received an unprecedented $25 million penalty. When a scandal like this occurs, institutions must also think about the possible reputational damage taking place. In this session, speakers will provide guidance on how to make the best of a bad situation by implementing decisive, corrective measures and steady following through.
Examination Walk-Through: Ensure Success with Step by Step Regulatory Guidance
An examination of your AML program and controls can be one of the most stressful experiences in your professional life. From the moment that you receive the first request letter, until you hear the results of the review, can seem like an eternity. However, most AML officers will agree that preparation is the key to survival. In this telling session, find out exactly what examiners expect so that you can make sure you have planned for every question and mapped out all the details. Regulators will give you tips to help you along each leg of the examination journey. After attending this panel, you will leave confident, now armed with the right tools you can implement the next time an examiner is knocking at your door.
Your Innovations in Investigative Tools: Map to the Information Super Highway
This engaging and informative panel features James Richards in an eye-opening presentation on using the internet in your AML work, including due diligence and internal investigations. Mr. Richards shows you how the Internet is an inexpensive and underutilized resource in money laundering controls. In an easy to follow format, he teaches you how to deftly navigate through the vast amounts of information to find what you need. Arrive at useful tools, such as the "invisible web" and "historical web," that can enhance your due diligence and AML investigations. Discover ways to unearth the many hidden and valuable nuggets of information the Web provides. And leave this session with a true account of the startling, powerful, and free information sources available to everyone - as long as you follow the correct path.
WORKSHOPS
MSBs: Smart Compliance by Risk Scoring Agents and Business Lines For years Money Services Businesses have been the target of regulatory agencies and law enforcement investigations. MSBs are perceived as having a disproportionately high level of risk due to the services they offer and their use of foreign correspondents in beneficiary countries. How do you convince a bank to look beyond years of unfair stereotyping of MBSs? Using different scenarios learn how to risk rank your own MSB across business lines. Also learn how to risk rank your foreign correspondents. Compare your findings with a bank’s risk assessment of the same MSB. This workshop will help you identify weaknesses within your current AML foundation and fortify your relationship with your banking partners.
Community Banks: Applying the Latest Transaction Monitoring Techniques on a Small Budget The Achilles’ heel of most community banks is the lack of funds and resources that they are allotted for AML controls. Although they are expected to comply in the same manner as other larger, more funded institutions, a small budget poses significant challenges. Especially since many money launderers are turning to smaller lower profile institutions to hide their illicit funds. When it comes to monitoring suspicious activity, there are many solutions, but how do you know which one is right for your community bank’s special needs? This workshop will help you choose whether an automated or manual solution is best for your institution. Once you have chosen the right solution, learn how to set up and maintain a transaction monitoring system that meets regulatory requirements, protects your institution and won’t break the bank.
Insurance: Identifying Red Flags to Strengthen Suspicious Activity Monitoring As Treasury and the IRS enforce the Bank Secrecy Act mandate regarding the insurance industry’s accountability for monitoring suspicious activity, some insurers remain unsure as to how to properly carry out the mandate. By looking to other industries as a guide, this interactive session will list some potential money laundering and terrorist financing red flags for the insurance industry. Work through mock scenarios and hone your skills at being able to pinpoint the suspicious behaviors. Once the indicators have been identified, our experts will guide you on how to maintain proper documentation of the incidents. See how retaining good records is the key to helping law enforcement with their investigations and that they will simultaneously help keep regulators from beating down your door.
Starting Off on the Right Foot with Risk Assessments for New Customers For years now, governmental bodies from around the globe have reinforced the importance of a risk-based approach when creating an effective AML and customer identification program. Financial institutions are now expected to risk rank their products, jurisdictions, and customers. For those organizations catering to high risk customers, not implementing a comprehensive and consistent risk assessment system can lead to disaster. In this session, gain the know-how and learn the proper steps to correctly evaluate your new customers by effectively rating their risks. Through detailed analysis of example customers, see how integrating risk assessments into account opening procedures can assure proper levels of due diligence. Use these risk-based procedures to fortify your customer identification program and create robust know your customer and enhance due diligence measures that will impress regulators and upper management.
"Very helpful for me as a brand new compliance officer." - Laurie Kelly, CAMS
CoBank AcB
Reach for the SARs - Law Enforcement Recommendations for Achieving SAR Perfection Suspicious activity reports are the foundation of a government’s defenses against money laundering and terrorist financing. When performed properly and with consistency, SARs can help stop launderers in their tracks. But a poorly drafted SAR is a burden to investigators and can catch the critical eye of examiners. In this session, hear from the law enforcement officials who see these reports everyday. Discover the right way to construct a SAR and the type of vital information that needs to be included in each report and its narrative section. You will be given sample mock SARs that you will dissect to find the weakness and how to correct the problems. See how improving the quality of your suspicious activity reporting will enhance its usefulness to law enforcement and will decrease the chances that regulators will find you at fault.
Scams and Schemes: Matching Wits with Innovative Criminals
Say what you will about money launderers, but one thing is for sure: they never stop trying to find new ways to tip toe around money laundering controls and squeak past law enforcement. Their scams can be a new spin on an old trick or can exploit the latest advances in technology as a way to move their dirty money. Either way, as an AML professional, part of your responsibility is to stay current with new money laundering schemes to guarantee that you are doing everything possible to keep these criminals at bay. In this workshop, take a hands-on look at recent case studies that involved new money laundering methods and techniques. Dissect these innovative ploys and by working together in groups, find new solutions to get the upper hand and help protect your institution against financial crime.
Between a Rock and a Hard Place: Meeting Regulatory Demands of U.S. Correspondent Banks International organizations that have US correspondent accounts must comply with the far-reaching USA Patriot Act, as well as their own regulations. This often puts them in a precarious position, including when it comes protecting the privacy of their customers’ data, that could explode into a negative regulatory action. How are foreign institutions handling the enhanced due diligence requirements that this law mandates to their U.S. correspondents? This workshop will examine real life scenarios that show how non-U.S. institutions manage the demands from U.S. correspondents. By dissecting these case studies, learn the appropriate steps you need to take when prioritizing the requests of your correspondent. Gain insight on how to make the right decisions that combine business logic and keep you in compliance with regulatory requirements.
SEMINARS
The Long Arm of the U.S. - Managing Contradicting, Regulatory Expectations
Anti-money laundering legislation from the United States isn’t always in harmony with regulations being implemented from other parts of the world. This can cause all kinds of headaches and sleepless nights for compliance officers working across multiple jurisdictions, not to mention problems that can arise when trying to comply with privacy laws while meeting AML requirements. This session will focus on four main regions -- Asia, Europe, Latin America and the Caribbean -- and the impact that US money laundering regulations have played in them. Panelists will dissect how the extraterritorial reach of US laws, such as the USA Patriot Act and Office of Foreign Assets Control sanctions, affect operations in their respective regions. Learn how compliance specialists cope when there are contradictions in the laws, and what this means during examination time.
Community Banks: Utilizing Advances in KYC Technology
Life for an AML officer working in a community bank has its challenges – many of them stemming from the fact that smaller banks don’t have the abundance of resources and support that large financial institutions boast. However, when it’s examination time, regulators usually have little sympathy. So how do you produce a robust compliance program and balance fiscal concerns? This session will explore the latest technologies and techniques when implementing Know Your Customer duties, including meeting customer identification program requirements, in a community bank. Find out how to assess the needs of your bank properly so that you are not paying for a solution that has bells and whistles that you just don’t need. Learn what solutions will enhance your bank’s compliance program and satisfy regulators but still keep you within your budget.
Electrify Your AML Program by Harnessing the Proactive Power of Your Own FIU The principal function of a government Financial Intelligence Unit (FIU) is to act as a nationally centralized agency that receives, analyzes and distributes information to financial institutions. This exchange of information is critical in assisting money laundering and terrorist financing investigations worldwide. Could employing this powerful resource provide the impetus to take your AML program to the next level? By incorporating the principles of a national FIU, you can recharge your own financial institution’s abilities to identify and handle risks. In this seminar, discover how to implement your own FIU structure from the ground up. See how an internal FIU can turn your department into an AML powerhouse that organizes and interprets large quantities of data to detect problems before they explode out of control.
MSBs: The Bottom Line on IRS Examinations and How to Make the Grade
As the money services businesses’ primary regulator, the IRS has responsibility for examining the AML programs of MSBs. Among these companies, however, there is much uncertainty about the expectations of an IRS Bank Secrecy Act Compliance Examination. MSBs continue to struggle with the high risk reputation because of concerns over lax AML controls. In this session, learn how the IRS examines MSBs and gain useful insight on how to ensure a favorable outcome. Review the new IRS examination guidelines to create a positive platform for an IRS examination. Also understand how the required independent review of your program can be a tool to ease regulators and foster a stronger banking relationship.
Risky Business: Serving Other Financial Institutions Without Jeopardizing Your Own
Many of those grouped within the Non Bank Financial Institutions (NBFI) classification – casinos, insurance companies, and money services businesses (MSBs) -- continue to struggle under the “too high risk to bank” label. Because of the perceived high-risk of their products or services, banks continue to turn them away. But not having these lucrative accounts as clients could have a huge impact on your bottom line. Which of these institutions are truly too risky? Even within just MSBs, FinCEN has released guidance saying that not all of these companies pose the same dangers. How do you weigh the money laundering risks and still make sound business decisions? This session will provide best practices on mitigating the risks associated with casinos, insurance, MSBs and other NBFIs, so that you can protect your institution without sacrificing profit.
To Bank or Not to Bank: Are PEPs Worth the Risk? Today’s AML officer is no stranger to the problem of politically exposed persons. These individuals usually hold senior positions that can fall into a range of categories – political figures, high-ranking military officials, senior executives of state-owned companies. PEPs also extend to the family members and close business associates of these individuals. With so many classifications, distinguishing a PEP can be an arduous process. Not all PEPs are corrupt, but banking a dangerous one can be a disaster for your institution and open you up to many liabilities. Using an analysis of case studies, experts will guide you through the steps to determine if your institution has a PEP and the decision making process that occurs afterwards. Learn how taking the proper enhanced due diligence measures can mitigate the risks and help protect your institution without negatively impacting your organization's proceeds.
Insurance: Transform Agents into Compliance Allies with Effective Training
In May 2006, the life insurance industry officially came under the AML umbrella and is now required to comply with Bank Secrecy Act (BSA) regulations. Insurers are expected to report suspicious activity and maintain a four point AML program, including assuring proper training for their agents. As anyone within the insurance industry will tell you, agents can be a huge liability. In this session, learn fundamental best practices for training independent agents as well as home office staff. When armed with the right tools, discover how training your agents can transform them from a risk into an asset, helping ensure that your insurance company fulfills regulatory requirements and is a model for top shelf AML compliance.
ROUNDTABLES
AML Directors: Orchestrating the Many Pieces of the Compliance Symphony
As AML guidelines increase and institutions are expected to comply with a growing list of regulations, directors are forced to make big decisions when it comes to issues such as staffing and implementation of AML programs. In this session, talk with other high-level leaders who have successfully executed new compliance strategies while balancing fiscal matters in their comprehensive corporate plan. Moreover, find creative ways to motivate your staff and boost morale so your employees will continue to fight the good fight.
Probing Shell Companies to Uncover Hidden Beneficiaries Ascertaining the beneficial owner of an account has always been one of the most challenging tasks a compliance officer will face. Digging through all the layers can be confusing and time-consuming, but necessary when facing enhanced due diligence mandates set forth by the U.S. Patriot Act. Here, learn what your peers are doing to penetrate shell companies to uncover the truth and the steps you should take after true beneficiaries are exposed.
Reaching Top-Notch AML Compliance in the Caribbean Region Financial institutions in the Caribbean have a reputation for being favored by corrupt politicians, money launderers and other criminals as places to hide their dirty money. Many of the countries in the region are also known as offshore jurisdictions. A majority of these institutions, because of the close proximity to the United States, have to maintain relationships with U.S. institutions as well. All these factors create a challenging environment in which to sustain successful AML compliance. At this roundtable, discuss specific issues with peers facing the same difficulties and come away with practical solutions.
"Excellent, well planned and very informative. I would highly recommend (it) to anyone within the AML industry. " - James E. Furry, CAMS
J. Edwards Associates
Community Banks: Sensitizing the Board of Directors to the Consequences of AML Non-Compliance
The board of directors at a community bank has many responsibilities, such as approving policies, maintaining proper oversight and allocating resources. But since a lot of boards are more concerned with balance sheets, how do you make them understand the serious ramifications that can come with noncompliance? See how other colleagues are utilizing their board as a valuable tool to help protect their institution from financial crime. Learn steps on how to effectively train and communicate to your board so they make informed decisions that yield positive results.
Insurance: Best Practices in Preparing for Regulatory Examinations
As the insurance industry’s primary regulator, the Internal Revenue Service (IRS) has been charged to examine them. A lack of guidance on examinations and training on the agency’s part, however, has left many insurance firms scratching their heads and crossing their fingers when it comes to passing regulatory reviews. In this roundtable, receive valuable advice from others within the industry on the best ways to prepare for a visit from regulators, so when it’s examination time, you’ll have the answers.
Emerging AML Issues Raised by Electronic Payment Systems As the global financial community becomes less reliant on cold hard cash and an increasing number of transactions are made through electronic payment systems, financial institutions need to adapt their AML policies to associated risks. Transactions made through electronic payment systems include cover payments, automated clearing house and other funds transfers. How do institutions fill in possible AML gaps, such as those with SWIFT payment messages and cover payments? What can you do to make sure that offering services, such as debit cards, does not put your institution in harms way? Share your views on these and other perplexing issues at this engaging roundtable discussion.
Face Time: Up Close with Your Regulator
Going through a regulatory review is certainly no walk in the park – it can be a seemingly interminable and nerve-racking experience. What can a compliance officer do to help minimize the stress? In this intimate debate, get face time with a regulator to ask all those burning questions that keep you up at night. Find out from an examiner what they look for when conducting a regulatory review. Also receive tips on how to manage and lessen the impact of a bad review.
Deciphering the ABC's of Sanctions List Many officials believe the best defense against terrorist financing is government watch lists. Many countries and organizations have them, including the United Nations, the European Union, the Bank of England and Canada. The Office of Foreign Assets Control (OFAC) in the U.S. has multiple lists that institutions must screen new customers and transactions against. This can create a complex and confusing situation, especially for multinational organizations. However, penalties such as the $60 million ruling against ABN Amro have proven this compliance area cannot be ignored. Here discuss best practices for staying on top of government watch lists, and tips for screening to guard against problems such as false positives.
Improve Your Training Track Record with Quality Assurance Good training is one of the essential elements of the four-pronged AML program, which is mandatory for financial institutions in most jurisdictions. Yet how do you assure the quality of the training to your senior management, regulators, and to other financial institutions that may require proof to maintain a relationship? Two possible solutions to this dilemma are testing and documentation. But which is right for your institution, and how do you implement them correctly? Compare notes with other AML specialists at this roundtable on what quality assurance methods will prove to regulators that your employees are properly trained.
Compliance Excellence in the Securities Industry
According to the U.S. National Association of Securities Dealers (NASD), enforcement actions surged 59 percent, to 71 actions in 2006 from 42 actions in the previous year. Those rulings centered on deficiencies in customer identification, independent testing, and filing to report structured transactions. With statistics like these, securities firms are scrambling to correct the deficiencies in their AML compliance programs before they are at the receiving end of an enforcement action. At this roundtable, confer with others who are feeling the same pressures to prefect their AML programs and trade best practices to help meet more stringent regulatory requirements.
MSBs: Defining Responsibilities of the Parent Company and Agents This roundtable will explore the regulatory roles and responsibilities for both the principle and MSB agent. Understand who is ultimately accountable for AML compliance duties, such as reportable transactions, filing SARs, training, and documenting agent policies. Learn how to better protect yourself from other risky activities that agents perform, like aggregated transactions and what to do if your agents are working for other vendors. Also, gain insight from your peers on a money remitter’s role in providing services.
Protect Against Information Technology Risks Through Better Training As the services offered by financial institution's move towards those that are more technologically based, their dependence on IT staff grows. In the past, many organizations didn’t give much thought to providing AML training for technology staff. However, in today’s ever-changing regulatory climate, it makes good compliance sense for a bank to protect itself from the possible regulatory risks associated with these employees. But where does IT fit into your compliance program and how much does IT have to be trained? Determine the answers to these questions and more at this thought-provoking and timely roundtable session.
