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2010 BSA/AML Compliance School
Every bank must provide ongoing training to those responsible for BSA and AML compliance. This school, co-sponsored by the Kentucky Bankers Association, gives your institution an opportunity to listen to and interact with regulators from the state and federal functional regulatory agencies as well as FinCEN and law enforcement. It also allows you a unique opportunity to get beyond the basics and get some rare “how to” instruction in BSA/AML compliance issues.
This is not an introductory program; all attendees should receive at least six hours of formal BSA/AML training prior to attending. The school's curriculum will change every year.
Attendance is limited. Please register early.
TUESDAY, JULY 13
8:30 - 9:00 AM Continental Breakfast
9:00 AM - FinCEN.
Keynote presentation from Jamal El-Hindi, Associate Director Regulatory Policy and Programs Division of the Financial Crimes Enforcement Network (FinCEN) addresses recent developments in U.S. anti-money laundering efforts. How does the current economic situation affect AML compliance, your institution, and your customers? Is there a nexus between fighting fraud and fighting money laundering? How can you leverage your limited resources and fine tune your risk based approach? The representative will also explain FinCEN’s multifaceted role in combating money laundering. It will be followed by a Q & A session where all attendees will have the chance to participate.
10:30 AM - Identifying and Managing High Risk Customers, Ken Golliher.
Okay, you have a list of high risk customers. First, can you defend the choices you made; i.e. is your method for choosing them objective or subjective? Second, do you have an objective or subjective method for removing a customer from the “high risk” list? Finally, now that you are confident you have identified the right customers, what are you going to do about it in terms of monitoring, documentation, and incorporating your conclusions into your risk assessment?
Noon: Lunch
1:00 PM SAR Decision Making, Ken Golliher
SAR filing decisions are the end result of one of the major compliance processes within your institution. That mechanism should involve a number of people and systems and it must take place every day without fail. It is totally dependent upon tangible due diligence and enhanced due diligence processes. This session will help attendees develop a process that leads to a good SAR filing decision; one your bank can document and defend.
2:45 PM Introduction to E Filing - Ken Janoski, FinCEN
A FinCEN representative describes “E-Filing,” the process that allows banks to file CTR, DOEP, and SAR forms electronically. The improved registration process and the proper administration of an e-filing program are reviewed in detail. Recent E-filing improvements such as the SAR validation program and the current statistics on banks and electronic filing are discussed.
4:00 PM - Program adjourns
WEDNESDAY, JULY 14
8:30 - 9:00 AM Continental Breakfast
9:00 AM The Appalachian HIDTA, Ed Shemelya.
Your bank’s formal risk assessment must take into account whether you have geographic connections to High Intensity Financial Crime Areas or High Intensity Drug Trafficking Areas (HIDTAs). This session, conducted by the head of the Appalachian HIDTA, is designed to inform attendees about the nature of the HIDTAs and their mission within their designated areas. Specifically, it provides a comprehensive overview of the Appalachian HIDTA as it relates to Kentucky. We will also discuss critical financial components of drug investigations and how bankers can assist the Appalachia HIDTA in fulfilling its mission.
10:45 AM Drilling Down to Find the Beneficial Owner, Ken Golliher
Recent guidance from FinCEN explains that due diligence includes an expectation that banks will identify the beneficial owners of entities that pose a heightened level of risk. For example, a corporation might be expected to identify its major shareholders, not just its officers and account signatories. This presentation reviews that guidance and makes a number of suggestions about how to integrate those queries into account inception and conduct reviews for existing customers as well.
Noon: Lunch
1:00 PM Regulatory Panel and Discussion
William Coulter, FRB
Dan Davis, OCC
Rick Marlin, OTS
John Talbert, Ky DFI
David Stahl, FDIC
Representatives from each of the federal functional regulatory agencies as well as the Kentucky Department of Banking have agreed to review their agencies’ current philosophies and practices. They will provide an overview of their agency’s current approach to BSA/AML examinations and attendees will have an opportunity to ask questions and participate in give and take discussions.
2:45 PM Preparing for your Independent Audit, Karen McCollum, CRCM, Internal Auditor, Bankers Service Corporation
It’s time for your annual BSA/AML Audit. How do you anticipate and maximize your bank's benefit from the process? Regulators continue to stress the importance of, and actually rely on the findings and follow-up of your annual Audit. This presentation will focus on preparing you for your next Audit, from pulling together request list items to alerting you of high priority review areas.
4:00 PM Program Ends
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