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Enhancing Compliance: Insights from the AMLA Third Annual BSA/AML Conference

This presentation by John M. Geiringer at the AMLA Third Annual BSA/AML Conference on October 4, 2013, addresses critical examination and enforcement issues in anti-money laundering (AML). Key topics include risk assessment, effective internal controls, independent testing, and the importance of a robust Customer Identification Program (CIP). The session emphasizes the need for ongoing training for employees and board members, tailored policies, and the implementation of comprehensive reporting systems to manage compliance and protect against risks in financial institutions.

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Enhancing Compliance: Insights from the AMLA Third Annual BSA/AML Conference

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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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