2016 BSA/AML/OFAC Training Series

Transcription

1 Session 1: April 21, 2016 at 9:00 a.m. Part I: AML Basics Junior/newly hired legal, compliance, audit, and operations 3 hours The session will address the (i) History of the Bank Secrecy Act; (ii) Regulatory Structure; (iii) Money Laundering Basics, Methodologies, and Trends; (iv) AML Risk Assessment; (v) AML Program; (vi) Customer Due Diligence; (vii) Account Monitoring; (viii) Suspicious Activity Identification and Reporting; (ix) Regulatory Reporting Requirements; and Part II: OFAC and Sanctions Programs Basics Junior/newly hired legal, compliance, audit, and back office (x) Independent Testing. 2 hours The session will address the (i) History and Purpose of the Economic Sanctions Programs; (ii) Overview of Current Sanctions Programs; (iii) Specially Designated Nationals and Blocked 1

2 Persons; (iv) OFAC Risk Assessment; (v) OFAC Compliance Program; (vi) Transaction Monitoring and Interdiction Software; (vii) Blocking vs. Rejecting Transactions; (viii) Reporting Obligations; (ix) Independent Testing; (x) Licensing; and (xi) OFAC Enforcement Guidelines. 2

3 Session 2: May 26, 2016 at 9:00 a.m. Identification and Management of Money Laundering and Terrorist Financing Risk Executives and legal, compliance, audit, customer representative, and operations 3 hours The session will address the (i) Elements of an Effective AML Risk Management Program; (ii) Risks Associated with the Customer Base; (iii) Risks Associated with the Products and Services Offered to Customers; (iv) Identification of Transaction- Based Risk; (v) Designations of Primary Money Laundering Concern; and (vi) On-Going Evaluation of AML Risk Management Program; and (vii) Role of Regulatory Guidance. 3

4 Session 3: June 23, 2016 at 9:00 a.m. Customer Due Diligence: Account Opening, Private Banking, and Politically Exposed Persons Legal, compliance, audit, customer representative, and operations 3 hours The session will address the (i) Minimum Customer Due Diligence Requirements; (ii) Special Due Diligence Requirements; (iii) Enhanced Due Diligence Requirements; (iv) Stratification of Customer Base; (v) High Risk Indicators; (vi) Due Diligence Requirements for Customers of Affiliates and Non-U.S. Branches; and (vii) Politically Exposed Persons/Senior Foreign Political Figures. 4

5 Session 4: September 22, 2016 at 9:00 a.m. Correspondent Banking Issues Legal, compliance, audit, customer representative, treasury, and operations 2 hours The session will address the (i) Minimum Due Diligence Requirements; (ii) Enhanced Due Diligence Requirements; (iii) Foreign Bank Certification; (iv) Senior Foreign Political Figures; (v) Relationship with Head Office and Non-U.S. Offices; (vi) Pouch Activities; (vii) Payable Through and Concentration Accounts (viii) Wire Transfer and ACH Activities; (ix) U.S. Dollar Clearing Activities; (x) Trade Finance Activities; and (xi) Transaction Monitoring. 5

6 Session 5: October 20, 2016 at 9:00 a.m. Part I: Suspicious Activity Monitoring Part II: Information Sharing Legal, compliance, audit, and operations Executives and legal, compliance, and audit 2 hours The session will address the (i) Suspicious Activity Reporting Requirements; (ii) Suspicious Activity and Red Flags (iii) Manual vs. Automated Monitoring; (iv) Investigation Procedures; (v) Escalation Procedures; (vi) Documentation of Monitoring and Filing Decisions; (vii) Sharing Suspicious Activity Reports within the Organization; and (viii) Case Studies. 1 hour The session will address the (i) Scope of Information Subject to Sharing; (ii) Responding to Government Requests; (iii) Sharing among Financial Institutions; (iv) Sharing within a Banking 6

7 Organization; and (v) Use of Information for Monitoring Purposes. Part III: SAR Case Study Legal, compliance, audit, and operations 1 hour Case study of how an SAR leads to law enforcement investigations, indictments, and criminal convictions for money laundering and terrorist financing. 7

8 Session 6: November 17, 2016 at 9:00 a.m. Part I: Function and Responsibilities of the BSA Officer BSA Officers 2 hours The session will address the (i) Primary duties; (ii) AML Risk Management; Part II: AML Training Programs BSA Officer and legal, compliance, and audit (iii) Management and Board Reporting; (iv) Evaluation of Staffing (levels and requisite expertise); (v) Relationship between Compliance and Internal Audit; (vi) Regulatory Reporting Requirements; and (vii) Training. 1.5 hours The session will address the (i) Types of Training; (ii) Assessing Training Needs; (iii) Integration of Monitoring Data and Trends; (iv) Sources of Training; and (v) Developing Function-Specific Training. 8

9 Session 7: December 15, 2016 at 9:00 a.m. Part I: Independent Testing and the Role and Function of Internal Audit Part II: Examination and Enforcement Overview Executives and legal, compliance, and audit Executives and legal, compliance, and audit 1 hour The session will address the (i) AML Audit Requirements (frequency and scope); (ii) Regulatory Expectations; (iii) Audit Independence; (iv) Competence of Audit Staff; (v) Use of Third Party or Head Office Auditors; and (vi) Management Response and Remediation. 2 hours The session will address the (i) Developing an Examination Strategy; (ii) First Day Letter; (iii) Assembling a Response to the First Day Letter; (iv) Preparation and Presentation of Materials; (v) Establishment of Examination Protocols; (vi) Addressing Issues during the Examination; 9

10 (vii) Post Examination Issues; and (viii) Potential Enforcement Actions; (ix) Enforcement Powers of Various Regulators; (x) Role of FinCEN; (xi) Law Enforcement Referral; (xii) Potential Consequences of Regulatory or Criminal Actions; and (xiii) Trends and Lessons Learned. 10