Regulators have ramped up BSA/AML citations during the past year, a trend that is expected to continue through 2014
Bankers are bracing for the start of more severe anti-money laundering exams as regulators rework their standards and prepare to issue another round of guidance tackling the issue. The agencies, notably the Office of the Comptroller of the Currency, are feeling the heat as lawmakers blame them for not doing enough to ensure institutions are following anti-laundering standards. Regulators are likely to make exams tougher for banks of all sizes, though officials have noted the most serious problems have arisen at the largest banks.
The agencies have put a renewed focus on forcing banks to know their customers’ entire banking relationship, as well as assess their existing and future risk. Just how much banks must know about their clients has been a source of contention for the past 13 years between banks and regulators, with some institutions arguing the agencies expect far too much. Banks failing to do the appropriate due diligence on a customer to comply with the Bank Secrecy Act could be symptomatic of broader compliance problems, including violation of consumer protection laws.
Most banks already have comprehensive systems in place to track suspicious activity. But knowing each customer and how to assess individual risk is more dependent on human judgment, and cannot be easily outsourced to a support system. Some observers said banks may have to improve their training of personnel to look deeper for potential violations.
We are pleased to announce that we have added a presentation by a Special Agent of Homeland Security Investigations (“HSI”) who will discuss how SARs have provided valuable information to solve and add value to HSI investigations. The Special Agent will discuss cases that were supported by filed SARs and share red flag indicators with the attendees to help identify criminal activity that flows through financial institutions.
The session will run from 8:30 to 4:00, with breakfast provided at 7:30.
Among the topics we will be looking at are:
- BSA exams – what are the regulators focusing on that keeps BSA Officers up at night about (i.e., heightened High risk client due diligence, frequency of reviews, new client on boarding due diligence, etc.)
- AML software validation and calibration of scenarios/rules
- Daily validation or balancing of bank core data (wires, ach, checks, deposits, cash, # of accounts, transfers, card activity, etc.) accurately flowing into AML software
- Banking Marijuana Dispensaries and indirect relationship (landlords that rent to Marijuana Dispensaries, manufacturer of hydroponic equipment utilized to grow marijuana)
- Emerging Payment delivery channels (what are the new methods and what are the risks posed to banks), such as digital wallet, square payments, lending clubs, etc.
- Virtual currency
- Sanctions (Iran, Syria and the next country to watch for Ukraine
- How SARs have provided valuable information to solve and add value to Homeland Security Investigations (“HSI”) cases
- BSA/AML Officers
- Compliance Officers and Managers
- Risk Managers
- Operations Managers
- Internal Auditors
- General Counsel
- Senior Bank Managers
The seminar will be presented by a faculty of consultants and regulators who will offer a wealth of experience in BSA and anti-money laundering. To date they include:
Christy Cornell-Pape, Case Manager-Special Activities, FDIC
Mark Levy, National Bank Examiner, OCC
Ryan Wakatsuki, National Bank Examiner, OCC (Southern CA)
Lawrence Carter, Assistant Deputy Comptroller, OCC
Tom Fleming, former Assistant Director for the Office of Compliance Financial Crimes Enforcement Network (FinCEN)
Brendan Brothers, Co-Founder, Verafin
Fred Casissa, Vice President/Senior Corporate AML Specialist FCRM – Controls, Testing & Evaluation, Union Bank
Elizabeth Slim, CAMS, SVP, BSA Officer, 1st Enterprise Bank
Special Agents from the Department of Homeland Security Investigations (HSI)
Early Bird Registration through Tuesday, May 27, 2014
CBA Member: $345
CBA Member: $445
Cancellation & Complaint Policy:
Substitutions are allowed, at no additional cost. Written notice is required for all substitutions/cancellations. The full registration fee will be refunded if the written request is received by Monday, June 2, 2014, and 50 percent if by Monday June 9, 2014. No refunds will be provided after June 9, 2014. Registrations made on or after June 9, 2014, are not subject to refund.
Complaints regarding this program should be directed to John Lingvall, VP & Director of Education, at (916) 438-4428.
Tuesday, June 24, 2014
The Westin San Francisco Airport
1 Old Bayshore Highway
Milbrae, CA 94030
BART to BSA!
CBA has arranged a special rate of $219/night. Please contact the hotel and reference the California Bankers Association by June 6, 2014 to reserve.
For transportation to and from the hotel, click here for detailed information.
CBA will host daily self parking.
Thursday, June 6, 2013
CBA has arranged a special rate of $149/night. Please call (877) 622-3056 or click https://resweb.passkey.com/go/CBAbsaaml by Wednesday June 11, 2014 to reserve.
CBA will host daily self parking.
Examiners and industry experts will discuss their approaches to BSA compliance in the current environment, and look at the implications of ongoing changes. We will focus on the practical in this session, giving you specific advice, examples, tools and best practices that you can apply back at your bank to better:
- Understand what’s new and evolving in the regulations
- Identify what examiners are focusing on and their expectations
- Practice the compliance fundamentals
- Describe the appropriate due diligence on a customer to comply with the Bank Secrecy Act
- Determine how to oversee third-party payment processor relationships and related products and services in a manner commensurate with associated risks
- Describe trends in enforcement and the consequences of non-compliance
- Understand the big picture including the implications of mortgage fraud, tax evasion, risk assessment and corruption
Program Level: Update for all levels
Advance Preparation: None
Method of Presentation: Group – Live (Lecture, Discussion, and Table Exercises)
Recommended CPE Credits: 6.0 Hours Maximum
(Estimated 2.0 Auditing, and 4.0 Specialized Knowledge and Applications)
Sponsored learning activities are measured by program length, with one 50-minute period equal to one CPE credit. One-half CPE credit increments (equal to 25 minutes) are permitted after the first credit has been earned in a given learning activity. Please note that not all state boards have adopted this rule. Some participants may not be able to use one-half credit increments.
Association of Certified Anti-Money Laundering Specialist
The Association of Certified Anti-Money Laundering Specialist ® (ACAMS) has been asked to approve the program for their certification requirements. Members of the ACAMS have the opportunity to earn approximately six (6) CAMS CE credits. For more information please visit www.ACAMS.org or contact firstname.lastname@example.org.
The Institute of Certified Bankers (ICB) is dedicated to promoting the highest standards of performance and ethics within the financial services industry. BSA/AML 2014 has been submitted for CFSSP and CRCM credits. This statement should not be viewed as an endorsement of this program or its sponsor. To report these credits, ICB members should visit www.icbmembers.org. We do not accept credit submissions from training providers on behalf of members.
Are Institute of Certified Bankers continuing professional education credits offered for this program?
Yes. In addition to the NASBA CPE credits, the Institute of Certified Bankers is certifying this program for credits toward their CRCM designation, as is the The Association of Certified Anti-Money Laundering Specialist.
Is group pricing available?
Yes. If you have three (3) or more people from your institution attending the program contact John Lingvall at email@example.com for information on how to register.