BSA / AML and OFAC – Continuing Developments
Some think that regulatory attention to the BSA has let up over the past couple of years, given other difficulties and areas of concern, such as mortgage lending.
Think again. With the safety and soundness of the entire industry the focus of news stories every day and well-publicized enforcement actions, the regulators obviously haven’t eased up. In fact, recent enforcement actions suggest risk assessments for BSA are still in focus.
We’ll talk about where the risk areas are in these rules, and where examiners are criticizing institutions. Your comprehensive program must be continually updated, and we’ll make sure you have the information you need to meet expectations.
- Updating your risk profiles, including due diligence
- Where regulatory attention is being placed
- Changes in funds transfers and BSA definitions
- Currency Transaction Reporting hotspots
- Suspicious Activity Reporting – the backbone of an effective BSA program, plus e-Filing
- Selling monetary instruments for cash – collecting and retaining information, plus the addition of gift cards?
- Funds transfer record keeping
- OFAC rules – who to screen?
- Blocked & rejected transactions – what’s the difference and how do I know which to do?
- Additional requirements, such as 314(a), PEPs, and Pouch activities
- Identifying customers and maintaining proper evidence under CIP rules
- FinCEN hotspots and areas for review
- And more
These rules impact most anyone in your institution who has direct dealings with customers, such as Customer Service Representatives and tellers. But others are impacted as well, like loan officers and others who make important customer-related decisions. Compliance officers, auditors, attorneys, and management too will benefit from this information, as well, as they often are the ones who must draft these complex programs, administer them, and audit them.
Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Managing Director for Treliant Risk Advisors in Washington, DC. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves on the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CE Credits
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