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Examination and Enforcement Issues: Beyond The Pillars

Examination and Enforcement Issues: Beyond The Pillars. The AMLA Third Annual Full Day BSA/AML Conference October 4, 2013 Presented by: John M. Geiringer john.geiringer@bfkn.com Chicago, Illinois (312) 984-3217. Risk Assessment. Size Complexity Geographic footprint Customer base

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Examination and Enforcement Issues: Beyond The Pillars

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  1. Examination and Enforcement Issues:Beyond The Pillars The AMLA Third AnnualFull Day BSA/AML Conference October 4, 2013 Presented by: John M. Geiringer john.geiringer@bfkn.com Chicago, Illinois (312) 984-3217

  2. Risk Assessment • Size • Complexity • Geographic footprint • Customer base • Products / services

  3. Elements • Internal controls to ensure ongoing compliance • Independent testing • Individual responsible for coordinating / monitoring compliance • Appropriate training for employees and directors • Customer Identification Program

  4. Internal Controls Policies, procedures and processes designed to limit and control risks and achieve compliance

  5. Internal Controls - Recommendations Policies and Procedures • Clearly written, comprehensive, and current • Organized and tailored • Useful to train others • Document evidence of adherence

  6. Internal Controls – Recommendations (cont.) Monitoring and Reporting System • Identification or alert of unusual activity • SAR decision-making, completion and filing • Escalation criteria to close account and notify law enforcement • Analysis of relationship when repeat SARs filed

  7. Independent Testing • Conducted either by internal audit department or qualified third party • Performed by individuals independent of compliance program • Conducted at least annually

  8. Independent Testing - Recommendations • Proper involvement of BSA Officer • Level of scope • Appropriate transaction testing • Assessment and validation of automated monitoring system • Results provided directly to Board

  9. BSA Officer • Board designates individual • Comprehensive knowledge of BSA and related regulations • Implements Board policies and directives • Coordinates and monitors day-to-day compliance • Ensures that employees adhere to policies, procedures and processes

  10. BSA Officer - Recommendations • Appropriate expertise, time, and resources • Periodically meet with employees across bank • Succession planning

  11. Training • Employees and directors receive appropriate training relevant to responsibilities • Comprehensive, ongoing and documented • Incorporates developments and changes

  12. Training - Recommendations • Include board of directors • Updated requirements • Compliance trends and hot topics • Changes to compliance program • Include policies and procedures • Documented and noted in minutes

  13. Customer Identification Program • Assess customer BSA risk at account opening • Develop understanding of normal and expected customer activity • Policy on account opening refusal and closing accounts • Monitor high risk accounts and compare anticipated to actual activity • Risk-based EDD procedures (cash businesses, service providers, PEPs, etc.)

  14. Questions?

  15. Examination and Enforcement Issues:Beyond The Pillars The AMLA Third AnnualFull Day BSA/AML Conference October 4, 2013 Presented by: John M. Geiringer john.geiringer@bfkn.com Chicago, Illinois (312) 984-3217

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