BSA/AML Literacy Test 1
|
|
- Kerry Parsons
- 6 years ago
- Views:
Transcription
1 BSA/AML Literacy Test 1 Please Note: The Basic Training consists of three videos approximately 15 minutes each, and should be viewed first. A lot of the following material is also to be found in the Basic Training. You also may be tested on material in the Basic Training. 1. What are the main goals of the BSA, and the AML statutes? (List as many as you can.) Congress passed the Bank Secrecy Act in 1970 as the first laws to fight money laundering in the United States. The BSA requires businesses to keep records and file reports that are determined to have a high degree of usefulness in criminal, tax, and regulatory matters. The documents filed by businesses under the BSA requirements are heavily used by law enforcement agencies, both domestic and international to identify, detect and deter money laundering whether it is in furtherance of a criminal enterprise, terrorism, tax evasion or other unlawful activity. 2 As amended over the years, the BSA's main purpose is to combat financial crime and protect the integrity of the financial system. Drug money and tax evasion were especially targeted. The cash economy was untaxed. Government developed the strategy of reining in the cash economy by using financial institutions as 'choke points' (s/b "Checkpoints.") The BSA made financial institutions responsible for recordkeeping and reporting on customer transactions over certain thresholds, especially those done in cash. Thus, all large payments in cash and large movements of money across US Borders were to be reported. To deprive criminals of anonymity, ID was to be taken. What was also targeted, were any transactions that might not be going through people's bank accounts. Beyond financial institutions, every US person was obliged to: report balances over $10,000 in foreign bank accounts, report receiving or paying cash over $10,000 in any trade or business, and report any cross border movements of money (the customs report). 2. What are the main dollar thresholds of the BSA applicable to the MSB industry? $1,000, $2,000, $3,000, $10, What vital pieces of customer information are required at each level? Five pieces of info: Name, Address, TIN, DOB, and ID - at $10k, add Occupation 4. In two words, what are the main requirements of the BSA? Recordkeeping and Reporting. 5. Why was it nicknamed the Bank Secrecy Act? Which banks? What secrets? This refers to foreign bank accounts US persons were holding, secret from the US government. 1 Applies to the United States, Only. 2 Taken from the IRS website.
2 6. What were the two major things missing from the BSA, which were added in 1986? Money laundering was made a federal crime for the first time, and structuring was prohibited.later, prohibitions on Unlicensed (state) and Unregistered (Federal) activity were added. 7. What are the main citations for the Bank Secrecy Act, "the AML statutes and FinCEN s Regs (Can you find them on the web?) BSA = 31USC 5311 et seq. AML Statutes = 18 USC 1956 et seq. FinCEN Regs = 31 CFR Chapter X (31CFR ) 8. What is the "cite" (citation) for the law that prohibits unlicensed activity, and what are its three prongs? 18 USC 1960 state licensing, federal registration, and any criminal activity. (1) the term unlicensed money transmitting business means a money transmitting business which affects interstate or foreign commerce in any manner or degree and (A) is operated without an appropriate money transmitting license in a State where such operation is punishable as a misdemeanor or a felony under State law, whether or not the defendant knew that the operation was required to be licensed or that the operation was so punishable; (B) fails to comply with the money transmitting business registration requirements under section 5330 of title 31, United States Code, or regulations prescribed under such section; or (C) otherwise involves the transportation or transmission of funds that are known to the defendant to have been derived from a criminal offense or are intended to be used to promote or support unlawful activity; 9. What are the 4 pillars of a compliance program and what section of what law do they come from? Briefly discuss the requirements of each one. Written policies and procedures Must be adequate and must reflect the compliance program that is actually followed. Officer - Must be knowledgeable and empowered Review Must be independent, i.e. not done by the same person who designed the program or the one who is responsible for administering it, day-to-day.
3 Training - Must keep training log that can be produced upon request, that shows who was trained and when, the content of the course, the name and qualifications of the instructor, and test score results, if any. 10. What is the recently added Fifth Pillar? Briefly describe it. See FinCEN's Final Rule on Customer Due Diligence 05/11/2016 It refers to legal entities, and relies on a customer self-certification. 11. What are the time limits for filing CTRs? SARs? MSB Registration? CTR - 15 days from the date of the transaction. SAR - 30 days from discovery of the suspicious activity. FinCEN Registration days from the start of the business. 12. What AML documents should be kept in a book of corporate documents? Corporate resolutions, re-adopted yearly, which include 1) Adoption of a General Statement of AML Policy, 2) Adoption of the AML compliance manual, and 3) The appointment of the Compliance Officer. 13. What are some other important documents a compliance officer should keep in a centralized location? The Training Log Suspicious Activity Reports A record of internal conversations about possible suspicious activity, and decisions taken. 14. What types of businesses are considered MSBs? Currency Dealers/Exchangers Check Cashers Money Transmitters and Issuers of checks, money orders etc. Prepaid Access providers and sellers, including plastic, mobile, internet Virtual Currencies 15. What are the differences in usage among the terms CIP, CDD, EDD, KYC and KYCC? CIP - Customer Identification Program: The term derives from Section 326 of the Patriot Act, technically applies only to depositories, and refers to taking ID and checking against OFAC list. CDD Customer Due Diligence is a broad term, similar to KYC. It is now used to describe the Fifth Pillar, FinCEN's "CDD" Rules. EDD Enhanced Due Diligence is what you must do on risky clients or transactions.
4 KYC A broad term which refers to the obligation every FI has to know their customer. KYCC Know your Customer's Customer, when you provide facilities to another FI. 16. To what extent is a financial institution responsible for knowing its customers? To an extent commensurate with the amount of the transaction, and the riskiness of the customer, type of transaction and relevant geography. 17. According to the BSA, what info is needed for a $3,500 transaction? Five pieces of info: Name, address, DOB, ID, SSN or TIN 18. What is the Travel Rule? Occurs at the $3,000 level. States that the originator's and beneficiary's FIs must take ID; all FIs in the chain must pass along all info; must respond if asked for the info by another FI in the chain. 19. What is the 120-hour rule? "Not later than 120 hours after receiving a request by an appropriate Federal banking agency for information related to anti-money laundering compliance by a covered financial institution or a customer of such institution, a covered financial institution shall provide to the appropriate Federal banking agency, or make available at a location specified by the representative of the appropriate Federal banking agency, information and account documentation for any account opened, maintained, administered or managed in the United States by the covered financial institution." - From Section 319(b)(2) of Title III of the USA Patriot Act. - Also see (b) re 314(a) FinCEN to specify time frame. 20. What is the primary federal requirement for MSBs, besides recordkeeping and reporting requirements of the BSA (note: this could be considered a type of report)? FinCEN MSB Registration. 21. What are the main requirements for the Risk-Based Approach? That a company should identify and evaluate its risks, prioritize them and take appropriate measures and dedicate adequate resources to mitigate and manage them. 22. According to the Risk-Based Approach, what are the 3 (or 4) major types of risk? Customer, Geographic, and Product (+ Operational Risk.) 23. What is the proper thing to do when a red flag is seen?
5 Ask more questions, do further investigation with appropriate follow-up action. 24. Is 18USC1960 considered a money laundering law? Yes. 25. What is the basic business model of Hawala? What is a parallel market? (MVTS or IVTS) "You pay my orders, I pay yours." Transactions done outside the formal financial system, where ID and records are optional. 26. What is the FinCEN Guidance on Foreign Agents and Counterparties? FinCEN's (Binding) Industry Guidance What are the 3 main Bibles of our compliance? The FFIEC BSA Exam Manual Its Core section, Expanded section, and Appendices The FinCEN/IRS Exam Manual + Workbook FATF's RBA for MSBs (or MVTSs ) 28. If you need to brush up on SAR capabilities, where do we find the instructions? Go to the e-filing section of the Fincen.gov website, and look for SAR Instructions. Also see various FinCEN Guidances and FAQs on the Topic. 29. What areas does the AML Compliance review cover? What does it seek to accomplish? Checking the company's Risk Assessment. Checking adequacy of the previous review and adequacy of the recommended follow-up actually done. Checking transaction records for compliance with the BSA, including quality of records and written materials. Checking all other elements of compliance with the BSA. Checking adequacy of management involvement, KYC policies and IT controls. Checking OFAC compliance. Checking adequacy of the Five Pillars. Checking adequacy of agent supervision and knowledge of foreign counterparty.
6 30. Why is the Dept of Treasury important? (The main reason for MSBs.) FinCEN is a bureau of the Treasury. 31. What are considered the Federal functional regulators? The Federal Reserve The Office of the Comptroller of the Currency The Federal Deposit Insurance Corporation The National Credit Union Administration The Securities Exchange Commission The U.S. Commodity Futures Trading Commission 32. Briefly explain the following important sections of the Patriot Act: Sections , Section 352, Section 326. ANSWER MISSING. 33. Outside of the BSA, what are some of the main bodies of federal and state law we must study? ANSWER MISSING. 34. Name some of the important FinCEN Guidances, Final Rules and other Issuances. ANSWER MISSING. 35. What is "aggregation?" See 31CFR "(a) Multiple branches. A financial institution includes all of its domestic branch offices, and any recordkeeping facility, wherever located, that contains records relating to the transactions of the institution's domestic offices, for purposes of the transactions in currency reporting requirements in this chapter. (b) Multiple transactions. In the case of financial institutions other than casinos, for purposes of the transactions in currency reporting requirements in this chapter, multiple currency transactions shall be treated as a single transaction if the financial institution has knowledge that they are by or on behalf of any person and result in either cash in or cash out totaling more than $10,000 during any one business day (or in the case of the U.S. Postal Service, any one day). Deposits made at night or over a weekend or holiday shall be treated as if received on the next business day following the deposit." The concept of aggregation appears in the basic Training. The aggregation period for CTR purposes is one business day for almost all financial institutions, one calendar day for the Post Office, and 24 hours for casinos.
7 Sometimes, when doing an exam, the IRS will look at a customer s 30-day cumulative transactions. The 2002 Western Union fine was suffered for not aggregating across agent locations. The only other aggregation period in the BSA relates to the Form 8300 (12 months, if the FI has knowledge they are related transactions). A company s aggregation policies have to draw together customer transactions from all business lines and channels, etc. Food for Thought: What are your company s time and amount thresholds to aggregate a customer's transactions over time? Has this been addressed in the Risk Assessment? 36. Define the following acronyms: AML ANPR BSA CIP CMIR CTR CTR EDD EIN FBAR FDL FFI Foreign Financial Institution FI Financial Institution FinCEN FIU GTO HIFCA/HIDTA IVTS Informal Value Transfer Services KYC KYCC MSB MSB-SAR MVTS - Monetary Value Transfer Services NPR OFAC PEP RA Risk Assessment RBA SAR SSN STR SUA
8 TIN UBO UBO USA Patriot Act - (This is an acronym.) 37. Define the following terms: Backing Down Compliance program Counseling Hawala Indictment Money laundering Offshore Refers to tax haven jurisdictions Paper Trail Program violation Red flag Risk Risk-Based Approach Smurfing Structuring Structuring Tipping off Transparency
Anti-Money Laundering and U.S. Compliance
U.S. Regulatory/Compliance Orientation for International Bankers Anti-Money Laundering and U.S. Compliance Conference of State Bank Supervisors & Institute of International Bankers New York City, New York
More informationTrans-Fast Remittance LLC. AML Compliance Training for Agents
Trans-Fast Remittance LLC AML Compliance Training for Agents 2016 Trans-Fast expects all of its agents to adhere to the following: terms of agent agreement; establish AML Program as per Section 352 of
More informationBank Secrecy Act and OFAC Compliance Board of Directors Training
Bank Secrecy Act and OFAC Compliance Board of Directors Training Introduction Today s presenters: Karen M. Janota Assurance Manager Disclaimer: The contents of this presentation are intended to provide
More information10 ESSENTIAL TERMS FOR BITCOIN REGULATION
In March 2013, the U.S. Financial Crimes Enforcement Network (FinCEN) classified Bitcoin and Virtual Currency exchanges as Money Services Businesses (MSB s) in the U.S., which are financial businesses
More informationBSA/AML Hot Topics and UIGEA Daniel Hastings Financial Institution Examiner - FDIC
BSA/AML Hot Topics and UIGEA Daniel Hastings Financial Institution Examiner - FDIC Common BSA Deficiencies Revised FFIEC BSA/AML Examination Manual Proposed CDD Requirements for Financial Institutions
More informationBSA/AML & OFAC Volunteer Compliance Training. Agenda
Ideas + Solutions = Success BSA/AML & OFAC Volunteer Compliance Training Ideas + Solutions = Success Presented by Dorie Fitchett HCUL Regulatory Officer May 17, 2018 Agenda 1. Bank Secrecy Act 2. Office
More informationANTI-MONEY LAUNDERING IN
ANTI-MONEY LAUNDERING IN THE ACQUIRING INDUSTRY Presented by Laura H. Goldzung, CAMS, CCFE, CFCF, CCRP AML Audit Services, LLC March 8, 2016 AGENDA AML Regulatory Overview OFAC Regulatory Overview AML
More informationIntroduction. Background on Money Laundering. Background on Terrorist financing. Bank Secrecy Act (Regulations)
XM - US Compliance Introduction Background on Money Laundering Background on Terrorist financing Bank Secrecy Act (Regulations) How MSB (Money Service Business) can help to prevent Money Laundering & Terrorist
More informationBSA/AML/OFAC for Bankers Jennifer Morrison Education Chair, COAFP for Buckeye Financial Forum, April 24, 2017
BSA/AML/OFAC for Bankers Jennifer Morrison Education Chair, COAFP for Buckeye Financial Forum, April 24, 2017 Disclaimer The following represents the opinions of the presenter, not those of my employer,
More informationSanctions Risk Management Symposium
What U.S. Federal Bank Examiners Look For in Their OFAC Compliance Examinations Tuesday, September 19, 2017, 10:30 11:15 AM Michaela Arndt Head, Sanctions Compliance, Americas and Group Head, US Sanctions
More informationThis Webcast Will Begin Shortly
This Webcast Will Begin Shortly If you have any technical problems with the Webcast or the streaming audio, please contact us via email at: webcast@acc.com Thank You! 1 The ABC s of AML: An Introduction
More informationCITIZENS, INC. BANK SECRECY ACT/ ANTI-MONEY LAUNDERING POLICY AND PROGRAM
I. Introduction CITIZENS, INC. BANK SECRECY ACT/ ANTI-MONEY LAUNDERING POLICY AND PROGRAM The Bank Secrecy Act/Anti-Money Laundering Responsibilities of Insurance Companies U.S. insurance companies have
More informationRegulatory Notice 17-40
Regulatory Notice 17-40 FinCEN s Customer Due Diligence Requirements for Financial Institutions and FINRA Rule 3310 FINRA Provides Guidance to Firms Regarding Anti- Money Laundering Program Requirements
More informationAGENT ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM FOR MONEY ORDER SALES
AGENT ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM FOR MONEY ORDER SALES Revision as of January 17, 2018 Explanation/Training Video Link: www.northamericanmoneyorder.com/aml This Program should be reviewed
More informationAnti-Money Laundering. How to set up a strong Compliance Program
Anti-Money Laundering How to set up a strong Compliance Program Importance of AML Protection Financial institutions face a growing number of threats from criminals that seek to misuse the U.S. financial
More informationBank Secrecy Act for Volunteers Southeast Leadership Development Conference Destin, Florida November 5, 2015
Bank Secrecy Act for Volunteers Southeast Leadership Development Conference Destin, Florida November 5, 2015 April N. Ales, BSACS, CCUFC, CUDE Overview of Presentation What Laws Govern Money Laundering
More informationAnti-Money Laundering and U.S. Compliance
Institute of International Bankers & Conference of State Bank Supervisors U.S. Regulatory/Compliance Orientation 2010 PATTON BOGGS LLP Anti-Money Laundering and U.S. Compliance New York City, New York
More informationBank Secrecy Act 101 Fall Colleen Kelly & Valerie Moss CUNA Compliance
Bank Secrecy Act 101 Fall 2016 Colleen Kelly & Valerie Moss CUNA Compliance BSA: COMBAT ILLICIT FINANCIAL TRANSACTIONS BSA Reporting Homeland Security: The only way to stop ISIS is to cut off their money
More informationTokenLot, LLC BSA Officer TokenLot, LLC Board of Directors
Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) Program APPROVED BY TokenLot, LLC BSA Officer TokenLot, LLC Board of Directors TokenLot, LLC BSA/AML Program 2017 1 TABLE OF CONTENTS 1. Bank Secrecy
More informationCUSTOMER DUE DILIGENC
CUSTOMER DUE DILIGENC of the Bank Secrecy Act Coverage: Federally insured credit unions Agency/Citation: FinCEN 31 CFR Parts 1010, 1020, 1023, 1024 and 1026 Effective Date: May 11, 2018 EXECUTIVE SUMMARY
More informationHow to Ace Your BSA Exam & Risk Assessment
How to Ace Your BSA Exam & Risk Assessment LeVar Anderson, CAMS, AAP Auditor, Carolinas Credit Union League Agenda NCUA Examiners review compliance with BSA as part of every exam cycle using examination
More informationBank Secrecy Act/ Anti-Money Laundering Examination Manual
Bank Secrecy Act/ Anti-Money Laundering Examination Manual Federal Financial Institutions Examination Council Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National
More informationFEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. ) ) ) ) ) ) ) ) ) )
FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. IN THE MATTER OF SHINHAN BANK AMERICA NEW YORK, NEW YORK (INSURED STATE NONMEMBER BANK CONSENT ORDER FDIC-16-0237b The Federal Deposit Insurance Corporation
More informationfor Boards 2015 Spring Leadership Development Conference
for Boards 2015 Spring Leadership Development Conference With Barb Boyd, CUCE Compliance Content Manager MCUL CU Solutions Group 1 AGENDA Purpose Compliance Culture Compliance Program Reporting Information
More informationPractical Suggestions for an Effective AML/OFAC Compliance Function
Practical Suggestions for an Effective AML/OFAC Compliance Function Institute of International Bankers 2013 Annual Anti-Money Laundering Seminar Paul S. Pilecki May 7, 2013 2013 Kilpatrick Townsend Recent
More informationPreparing for Your BSA Compliance Exams. Ted Dreyer, Senior Attorney Wolters Kluwer
Preparing for Your BSA Compliance Exams Ted Dreyer, Senior Attorney Wolters Kluwer Scoping And Planning of Exam BSA/AML Examination Manual Overview Examination procedures First thing on list Previous Criticism
More informationBank Secrecy Act- USA Patriot Act Compliance
Bank Secrecy Act- USA Patriot Act Compliance Federal Laws Regulating Money Service Businesses Bank Secrecy Act (1970) Establishes recording of high dollar transactions & the reporting of suspicious activity
More informationBank Secrecy Act & Anti-Money Laundering for Directors. Mike Lee Director of Regulatory Advocacy
Bank Secrecy Act & Anti-Money Laundering for Directors Mike Lee Director of Regulatory Advocacy michael.lee@lscu.coop Legal Disclaimer: Information provided in this presentation, including all materials,
More informationa. Domestic money laundering statutes and laws i. Bank Secrecy Act of 1970
HIGH- STAKES TAX DEFENSE & COMPLEX CRIMINAL DEFENSE 1012 Broad Street, 2nd Fl Bloomfield, NJ 07003 Tel (973) 783-7000 Fax (973) 338-3955 www.deblislaw.com Anti- Money Laundering Tools a. Domestic money
More informationAnti-Money Laundering and Terrorist Financing Prevention Compliance Program Creation Guide
Anti-Money Laundering and Terrorist Financing Prevention Compliance Program Creation Guide Compliance Program Creation Guide January 2015 1 Compliance Program Creation Guide January 2015 2 Insert Business
More informationDevelopments in Anti-Money Laundering Regulation for Investment Advisers and Funding Portals. May 2016
Developments in Anti-Money Laundering Regulation for Investment Advisers and Funding Portals May 2016 John L. Sullivan Washington, D.C. jlsullivan@wsgr.com Michael Chiswick-Patterson Washington, D.C. mchiswickpatterson@wsgr.com
More informationBank Secrecy Act. CUNA Must Know Mondays. November 17, 2014
Bank Secrecy Act CUNA Must Know Mondays November 17, 2014 1 David A. Reed Attorney at Law Reed & Jolly, PLLC Fairfax, Virginia david@reedandjolly.com (703) 675-9578 2 2 The contents of this presentation
More informationFederal Reserve Bank of Dallas
ll K Federal Reserve Bank of Dallas 2200 N. PEARL ST. DALLAS, TX 75201-2272 October 31, 2003 Notice 03-63 TO: The Chief Executive Officer of each financial institution and others concerned in the Eleventh
More informationAnti-Money Laundering and Terrorist Financing Prevention Compliance Program Creation Guide
Anti-Money Laundering and Terrorist Financing Prevention Compliance Program Creation Guide Insert Business Name Here Date of Adoption of this Anti-Money Laundering Program ANTI-MONEY LAUNDERING AND TERRORIST
More informationBank Secrecy Act for Directors
Bank Secrecy Act for Directors Agenda What is the Bank Secrecy Act? How to have a successful BSA Compliance Program? OFAC responsibilities. Penalties for non-compliance. 2 What is the Bank Secrecy Act?
More informationOklahoma Agent Compliance Training Guide
Anti-Money Laundering Compliance Guide USA PATRIOT Act Prevention of Terrorism Financing Oklahoma Agent Compliance Training Guide Reporting Requirements Recordkeeping FinCEN Resources Employee Training
More informationBank Secrecy Act Anti-Money Laundering Examination Manual
Federal Financial Institutions Examination Council Bank Secrecy Act Anti-Money Laundering Examination Manual Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National
More informationBank Secrecy Act Examination Procedures. Sections 313, 314, and 319(b) of the USA PATRIOT Act (31 CFR , , , 103.
Bank Secrecy Act Examination Procedures Sections 313, 314, and 319(b) of the USA PATRIOT Act (31 CFR 103.100, 103.110, 103.177, 103.185) Table of Contents Correspondent Accounts for Foreign Shell Banks
More informationfinancial intelligence centre REPUBLIC OF SOUTH AFRICA Financial Intelligence Centre FAIS Workshop Presented by The Financial Intelligence Centre
Financial Intelligence Centre FAIS Workshop Presented by The Financial Intelligence Centre 3 December 2013 Agenda The FIC Functions of the FIC Value Chain FIC - 2012/2013 in review Compliance framework
More informationDEVELOPMENT BANK OF IRAN (EDBI)
EXPORT DEVELOPMENT BANK OF IRAN (EDBI) Anti-Money Laundering and Combating Financing of Terrorism Policies Target audience: Employees and Management of EDBI Approved by: EDBI s Board of Directors, at 2018/05/21
More informationUNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK ASSESSMENT OF CIVIL MONEY PENALTY
UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK IN THE MATTER OF: ) ) ) ) Number 2017-02 Merchants Bank of California, N.A. ) Carson, California ) ASSESSMENT OF
More informationAnti-Money Laundering
INFORMATIONAL Anti-Money Laundering NASD Provides Guidance To Member Firms Concerning Anti-Money Laundering Compliance Programs Required By Federal Law SUGGESTED ROUTING The Suggested Routing function
More informationPrepaid Cards Federal Law Issues and Developments
Prepaid Cards Federal Law Issues and Developments Donald J. Mosher, Partner, Schulte Roth & Zabel LLP 1 This information has been prepared by Schulte Roth & Zabel LLP for general informational purposes
More informationDefinitions AML/BSA Risks Assess Your Risks Identify the Risks Mitigate the Risks Scenario Questions?
Definitions AML/BSA Risks Assess Your Risks Identify the Risks Mitigate the Risks Scenario Questions? 2 BSA Bank Secrecy Act Currency and Foreign Transactions Reporting Act, is legislation passed by the
More informationFinancial Institutions Webinar: AML Regulation and Enforcement What to Expect, How to Prepare
Financial Institutions Webinar: AML Regulation and Enforcement What to Expect, How to Prepare June 22, 2017 Sharon Cohen Levin, Partner, Jeremy Dresner, Counsel, Attorney Advertising Speakers Sharon Cohen
More informationLawyer Insights. AML and Sanctions Compliance Issues Facing Cryptocurrency Companies. June 4, by Richard S. Garabedian and Shaswat K.
Lawyer Insights June 4, 2018 AML and Sanctions Compliance Issues Facing Cryptocurrency Companies by Richard S. Garabedian and Shaswat K. Das Published in Crowdfund Insider Over the past few years, continued
More informationBank Secrecy Act for Operations Staff
Bank Secrecy Act for Operations Staff Presented by Jan Vogel, Center for Professional Development WilliamsTown Communications, Contributing Writer #TR1118 l Introduction Welcome to CUNA s Bank Secrecy
More informationUNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY COMPTROLLER OF THE CURRENCY CONSENT ORDER
EX-99.2 3 wafd8-kexhibit992order.htm EXHIBIT 99.2 Exhibit 99.2 UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY COMPTROLLER OF THE CURRENCY In the Matter of: Washington Federal, National Association
More informationBank Of America Corporation Aml Policy Manual
Bank Of America Corporation Aml Policy Manual American Gaming Association. Best Practices Bank Secrecy Act and associated anti-money laundering (AML) statutes and regulations. Risk- The goal of this document
More information2015 Bank Secrecy Act
2015 Erin O Hern, Director of League Compliance Services The services of PolicyWorks and this presentation, including all materials, should not be construed as legal services, legal advice, or in any way
More informationBeneficial Ownership Rules. Iowa Bankers Association
Beneficial Ownership Rules Iowa Bankers Association November 2017 TABLE OF CONTENTS Program Description and Purpose... 1 FinCEN s Regulation X Beneficial Ownership... 2 Definitions... 3 BSA/AML Program
More informationFinCEN s Customer Due Diligence Requirements: Final Rule. Washington Bankers Association October 6, 2017
FinCEN s Customer Due Diligence Requirements: Final Rule Washington Bankers Association October 6, 2017 Bankers Forum Call Objectives: Discuss four key elements of FinCEN s Customer Due Diligence Final
More informationUnited States Agent Compliance Training Guide
Anti-Money Laundering Compliance Guide USA PATRIOT Act Prevention of Terrorist Financing United States Agent Compliance Training Guide Reporting Requirements Recordkeeping FinCEN Resources Employee Training
More informationU.S. Department of Justice National Drug Intelligence Center. A Potential Alternative to Traditional Money Laundering Methods
U.S. Department of Justice National Drug Intelligence Center Assessment Product No. 2006-R0803-001 Prepaid Stored Value Cards: A Potential Alternative to Traditional Money Laundering Methods 31 October
More informationBSA Regulatory Discussion on Emerging Issues. Salt Lake City ACAMS Chapter Meeting June 21, 2018
BSA Regulatory Discussion on Emerging Issues Salt Lake City ACAMS Chapter Meeting June 21, 2018 Today s Discussion FinCEN s Customer Due Diligence Rule AML Monitoring Systems Providing Services to Marijuana
More informationBank Secrecy Act Hot Topics!
Bank Secrecy Act Hot Topics! Barb Boyd, Glory LeDu, Sarah Stevenson, Mary Jo White Bank Secrecy Act Hot Topics What Changed in 2014? Guidance on Virtual Currency (1/31/14) Virtual Currency Rulings (10/28/14)
More informationBank Secrecy Act. The board establishes adequate policies and procedures in accordance with anti-money laundering laws and regulations.
Bank Secrecy Act Standards Examiners should evaluate the above-captioned function against the following control and performance standards. The Standards represent control and performance objectives that
More informationBank Secrecy Act OFAC FinCEN
Bank Secrecy Act OFAC FinCEN 2017 CREDIT UNION VOLUNTEER TRAINING Financial Crimes Identify Track Report Common BSA Acronyms CIP CDD CTR SAR FinCEN OFAC Customer Identification Program Customer Due Diligence
More informationForeign Financial Institutions Anti-Money Laundering Questionnaire
SECTION I - GENERAL ADMINISTRATIVE INFORMATION 1. Legal Name of Financial Institution D/B/A (if applicable) 2. Registered Address (attach proof) Physical presence at this address? o Yes o No 3. Head Office
More informationANTI-MONEY LAUNDERING COMPLIANCE GUIDE
ANTI-MONEY LAUNDERING COMPLIANCE GUIDE Revision as of January 17, 2018 This revision supersedes and replaces all other Anti-Money Laundering Compliance Guides issued by North American Money Order Company,
More informationACFE and ACAMS South Florida Chapter 2015 AML/Fraud Conference
ACFE and ACAMS South Florida Chapter 2015 AML/Fraud Conference Marc Benson Director, Global Investigations & Compliance Navigant Consulting Inc. Salvatore LaScala Managing Director, Global Investigations
More informationUNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK
UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK IN THE MATTER OF: ) ) ) ) Number 2017-04 Lone Star National Bank ) Pharr, Texas ) ASSESSMENT OF CIVIL MONEY PENALTY
More informationAnti-Money Laundering Awareness Training Insurance Industry-Hong Kong
Anti-Money Laundering Awareness Training Overview This program is intended to give individuals working in the Hong Kong Insurance Industry a basic knowledge of money laundering and terrorism financing,
More informationIdentify and Monitor High- Risk and Money Service Businesses Accounts. Presented by Lynn English Lafayette Federal Credit Union
Identify and Monitor High- Risk and Money Service Businesses Accounts Presented by Lynn English Lafayette Federal Credit Union Key Takeaways After this webinar, participants should have an understanding
More informationCOMPLIANCE MANAGEMENT: THE ART OF BOARD REPORTING
COMPLIANCE MANAGEMENT: THE ART OF BOARD REPORTING 2015 Temenos USA, Inc. All rights reserved. Leah M. Hamilton Chief Compliance Officer, TriComply Services WHAT YOU WILL LEARN: 2 How to write a Board Report
More information9 THE US REGULATORY FRAMEWORK
Handbook of Anti Money Laundering By Dennis Cox 2014 John Wiley & Sons, Ltd 9 THE US REGULATORY FRAMEWORK This chapter provides an overview of the USA regulatory framework. Additional information on the
More informationCustomer Identification Programs, Anti-Money Laundering Programs, and. Beneficial Ownership Requirements for Banks Lacking a Federal Functional
This document is scheduled to be published in the Federal Register on 08/25/2016 and available online at http://federalregister.gov/a/2016-20219, and on FDsys.gov BILLING CODE 4810-02 DEPARTMENT OF THE
More information1. ENTITY & OWNERSHIP 1 Full Legal Name
Financial Institution Name: Location (Country) : No # Question Answer 1. ENTITY & OWNERSHIP 1 Full Legal Name 2 Append a list of branches which are covered by this questionnaire 3 Full Legal (Registered)
More informationJamie L. Howell, CUCE
Bank Secrecy Act Jamie L. Howell, CUCE 20 years in credit unions; has worked with dozens of CUs worldwide Specializing in training & education Credit Union Compliance Expert (CUCE) since 2006 Spent 2+
More informationBENEFICIAL OWNERSHIP REFERENCE GUIDE
Sterling COMPLIANCE BENEFICIAL OWNERSHIP REFERENCE GUIDE FACILITATE THOUGHT ENGAGE DIALOGUE ENCOURAGE SMART RISK CULTIVATE A NETWORK BUILD KNOWLEDGE IN THIS GUIDE The documents within this package were
More informationBSA CDD/EDD and Beneficial Ownership and other BSA Hot Topics
BSA CDD/EDD and Beneficial Ownership and other BSA Hot Topics Kelan Oster koster@eidebailly.com 701-239-8682 Agenda Customer Due Diligence Requirements for Financial Institutions CDD/EDD New Rule what
More informationAgent Compliance Manual. For Caribbean Airmail, Inc. Bank Secrecy Act Anti Money Laundering OFAC USA PATRIOT ACT CFPB July 2014
Agent Compliance Manual For Caribbean Airmail, Inc. Bank Secrecy Act Anti Money Laundering OFAC USA PATRIOT ACT CFPB July 2014 May Not Be Used Or Disclosed Outside Caribbean Airmail Inc Without Management
More informationANTI-MONEY LAUNDERING TRAINING FOR AGENTS TRANSAMERICA LIFE & PROTECTION
ANTI-MONEY LAUNDERING TRAINING FOR AGENTS TRANSAMERICA LIFE & PROTECTION Division of the following Statutory Companies: TRANSAMERICA FINANCIAL LIFE INSURANCE COMPANY TRANSAMERICA LIFE INSURANCE COMPANY
More informationRegulatory Notice 18-36
Regulatory Notice 18-36 Capital Acquisition Brokers FINRA Amends Capital Acquisition Broker Rule 331 to Conform to FinCEN s Final Rule on Customer Due Diligence Requirements for Financial Institutions
More information1. ENTITY & OWNERSHIP 1 Full Legal name
Financial Institution Name: Location (Country) : JPMorgan Chase & Co. Global No # Question Answer 1. ENTITY & OWNERSHIP 1 Full Legal name 2 Append a list of branches which are covered by this questionnaire
More informationAUTO-OWNERS ASSOCIATES CREDIT UNION POLICY AND PROCEDURES MANUAL
Reviewed/Approved by Board of Directors: September 20, 2011 Page 1 of 16 BSA/AML Compliance Auto-Owners Associates Credit Union s (AOACU) Bank Secrecy Act (BSA) Program will include internal policies,
More informationA MONEY LAUNDERING OVERVIEW
A MONEY LAUNDERING OVERVIEW Committee on Financial Institutions Representative Jennifer Carroll Chair Representative Garrett Richter Vice Chair January 2008 TABLE OF CONTENTS I. INTRODUCTION 1 II. NATIONAL
More informationLaw. The Civil Justice System Association of Certified Fraud Examiners, Inc.
Law The Civil Justice System 2016 Association of Certified Fraud Examiners, Inc. Civil Litigation Beginning the Civil Action Filing the Complaint Jurisdiction Grounds for relief (what are you suing for,
More informationFinCEN Proposes to Expand Financial Institution Customer Due Diligence Requirements
August 5, 2014 FinCEN Proposes to Expand Financial Institution Customer Due Diligence Requirements The proposal would require financial institutions to identify beneficial owners of legal entities and
More informationUNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK
UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK ZIONS FIRST NATIONAL BANK SAL T LAKE CITY, UTAH Under the authority of the Bank Secrecy Act ("BSA") and regulations
More informationTaiwan Shin Kong Commercial Bank Co., Ltd. (Shin Kong Bank) 21F, No.36, Songren Road, Xinyi District, Taipei, Taiwan
Financial Institution Name: Location (Country) : Taiwan Shin Kong Commercial Bank Co., Ltd. (Shin Kong Bank) 21F, No.36, Songren Road, Xinyi District, Taipei, Taiwan The questionnaire is required to be
More information1. ENTITY & OWNERSHIP 1 Full Legal Name
Financial Institution Name: Location (Country) : The questionnaire is required to be answered on a Legal Entity (LE) Level. This means the Financial Institution will answer the questionnaire at an ultimate
More informationProtecting Native American casinos from money-laundering risks
Protecting Native American casinos from money-laundering risks For the vast majority of patrons, Native American casinos are ideal destinations for entertainment and leisure. Casinos are cash-intensive
More informationTHE LINE IN THE SAND: FRAUD AWARENESS, PREVENTION, & DETECTION THE FOUR COMPONENTS OF A SUSPICIOUS ACTIVITY PROGRAM
THE LINE IN THE SAND: FRAUD AWARENESS, PREVENTION, & DETECTION THE FOUR COMPONENTS OF A SUSPICIOUS ACTIVITY PROGRAM In the latest update by the Federal Financial Institutions Examination Council of the
More informationBank Secrecy Act for Consumer Lending Staff
Bank Secrecy Act for Consumer Lending Staff Hello, and welcome to CUNA s Bank Secrecy Act for Consumer Lending Staff Training on Demand course! Compliance with the Bank Secrecy Act, otherwise known as
More informationTHE USA PATRIOT ACT New Responsibilities for Institutions in the Financial Industry
P THE USA PATRIOT ACT New Responsibilities for Institutions in the Financial Industry By Michael P. Malloy 2002. Reproduced by permission. resident Bush signed into law the Uniting and Strengthening America
More informationLiberty Bankers Life Insurance Company
Liberty Bankers Life Insurance Company Anti-Money Laundering (AML) Policy Introduction In compliance with the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and
More informationCUSTOMER DUE DILIGENCE (CDD) & ANTI-MONEY
CUSTOMER DUE DILIGENCE (CDD) & ANTI-MONEY LAUNDERING (AML) / COMBATING FINANCING OF TERRORISM (CFT) POLICY MCB SRI LANKA OPERATIONS 2017 Version 2.0 For Internal Use Only Document Control Sheet Title Of
More information1. ENTITY & OWNERSHIP 1 Full Legal name
Financial Institution Name: Location (Country) : ING Bank N.V. The Netherlands No # Question Answer 1. ENTITY & OWNERSHIP 1 Full Legal name 2 Append a list of branches which are covered by this questionnaire
More informationBank Secrecy Act (BSA)/Anti-Money Laundering (AML) Employee & Agent Training
Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) Employee & Agent Training OVERVIEW The Bank Secrecy Act, or BSA, was passed by congress in 1970. The BSA required banks to maintain records of certain
More informationANTI MONEY LAUNDERING LAWS IN THE UNITED STATES
ANTI MONEY LAUNDERING LAWS IN THE UNITED STATES July 2013 Michael Wu, Research Assistant Shirley Yeung, Research Assistant Limited 801, Two Exchange Square, 8 Connaught Place, Central, Hong Kong Tel: (852)
More informationMoney Laundering: Suspicious Activity Reports
strategies from numbers Money Laundering: Suspicious Activity Reports What you Need to Know & Florida Institute of Certified Public Accountants Presentation José I. Marrero, EA Luis O. Rivera, CPA, CFF,
More informationBank Secrecy Act (BSA) and Anti-Money Laundering (AML) Policy and Program for BancStar, Inc. Affiliated Banks
Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) Policy and Program for BancStar, Inc. Affiliated Banks Reviewed and Approved by Board of Directors on: Bank Star One 09/18/14 Bank Star 09/26/14 Bank
More information1. ENTITY & OWNERSHIP 1 Full Legal name
Financial Institution Name: Location (Country) : BNP PARIBAS 16, Boulevard des Italiens - 75009 Paris FRANCE # Question Answer 1. ENTITY & OWNERSHIP 1 Full Legal name 2 Append a list of branches which
More informationAML Best Practices for Investment Advisers and Broker/ Dealers. July 7, :00 p.m. to 3:00 p.m. (ET) 2016 National Regulatory Services
AML Best Practices for Investment Advisers and Broker/ Dealers July 7, 2016 2:00 p.m. to 3:00 p.m. (ET) 2016 National Regulatory Services Instructor Jennifer Sullivan Jennifer Sullivan Consultant NRS Lakeville,
More informationRecent Changes to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual
Recent Changes to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual Recent Changes to the FFIEC Bank Secrecy Act / Anti-Money Laundering (BSA / AML) Examination Manual For quite
More informationTHE BSA COALITION PRESENTS: Highlights of and Lessons Learned from the 2014 Landscape
THE BSA COALITION PRESENTS: Highlights of and Lessons Learned from the 2014 Landscape April 15, 2015 James Candelmo Executive Compliance Director and BSA/AML Officer Ally Financial Amanda Tucker Executive
More informationCUSTOMER DUE DILIGENCE (CDD) & ANTI-MONEY LAUNDERING (AML) / COMBATING FINANCING OF TERRORISM (CFT) POLICY (2012)
CUSTOMER DUE DILIGENCE (CDD) & ANTI-MONEY LAUNDERING (AML) / COMBATING FINANCING OF TERRORISM (CFT) POLICY (2012) Version: 1.1.1 Date of Revision: 30-Oct-2012 Compliance and Controls Group Page 1 INTRODUCTION:
More informationBSA Excellence: Officer Training
Welcome to BSA Excellence: Officer Training 1 Compliance Outsourcing Partnership Solutions The Karen I. Martino Group COPS A Partner Only Firm Specializing in: BSA Independent Third Party Audits Compliance
More informationOCC Policy Statement on Tax Refund-Related Products
OCC Policy Statement on Tax Refund-Related Products The Office of the Comptroller of the Currency (OCC) is issuing the following policy statement setting forth the measures national banks are expected
More information