Overview

On September 4th 2024 FinCEN published its Final Rule designating Registered Investment Advisers (RIAs) as financial institutions under the Bank Secrecy act thereby requiring them to have a BSA/AML Program.  The role of RIAs,  like Relationship Managers (RMs) in business lines such as Corporate or Private Banking requires that the RIA or RM form a close relationship with their clients.  A key parallel is that the RIA’s or RM’s compensation may be directly tied to value of Assets Under Management (AUM) or the products or services that the client uses, creating a potential conflict for the RIA or banker should the client or funds be tainted.  The FFIEC BSA/AML Exam Manual’s section on Due Diligence requirement for Private Banking Relationships Accounts has long recognized these close relationships and include a reference to Investment Advisers within Appendix N.

The purpose of this webinar will be to explore the conflicts that arise between "the business" and Compliance when it comes to managing client accounts.  We will explore ways to navigate these conflicts, how to incorporate compliance into the customer relationship and how to manage RMs who go rogue.