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A manual designed to encompass the broad range of topics included in the realm of the Bank Secrecy Act and Anti-Money Laundering.
- Anti-Money Laundering Act (AMLA 2020) Implementation
- Customer / Member Due Diligence – The Program and the Process
- Suspicious Activity Reporting (SAR) – (FinCEN Form 111) and reporting Suspicious Activity
- Establishing a Risk-Based Program of Identifying and Classifying Your Customers / Members
- Overview of Regulatory and Statutory Components of BSA
- Updated Examination Procedures
- Information Sharing (314 (a) & (b)) and Other Title III Programs
- Completing the Currency Transaction Report (FinCEN Form 112)
- Exempting Eligible Customers / Members from the CTR Filing (Form 110)
- Pandemic-Related Fraud Schemes
- How OFAC Fits into the Process – the Sanctions Compliance Program (SCP)
- Establishing the Appropriate Culture of Compliance
Recent Congressional focus and well-publicized BSA enforcement actions and fines continue to support a climate proving BSA compliance remains of paramount importance to all financial institutions. Treasury continues to rely on financial institutions to serve as the “front-line gatekeepers” for law enforcement efforts to safeguard the U.S. financial system from the abuses of financial crimes, including money laundering and terrorist financing. The federal regulatory agencies continue to rely on financial institutions to take “every reasonable step” to identify, minimize, and manage any risks that illicit financial activity may pose to the individual institution and the industry. Ongoing initiatives by the Financial Crimes Enforcement Network (FinCEN), and continued expansions of the federal examination procedures, reinforce the need to have a strong BSA program at your institution.
This manual covers in detail the issues and opportunities in the ever-expanding environment of the Bank Secrecy Act and reviews the entire realm of BSA from “A” to “Z”. From decades old Currency Transaction Reporting (CTR) and various record keeping requirements, to institutional risk assessment, customer/member due diligence (CDD), beneficial ownership expectations, and suspicious activity reporting, students from the novice appointee to the tenured BSA professional will find the discussions and interactions to be of great value.
- Latest on AMLA 2020 Implementation;
- Statutory and Regulatory Requirements;
- Enforcement Actions, MRIAs, and the “Lessons Learned”;
- Acronym Review and Sources of Information;
- Proposed Regulatory Changes – Status;
- USA PATRIOT Act Requirements and Implications;
- Currency Transaction Reporting – FinCEN Form 112;
- Exemption “Opportunities” From CTR Reporting;
- Record keeping Requirements;
- Office of Foreign Assets Control (OFAC) – Sanctions Compliance Program (SCP) Framework;
- Culture of Compliance;
- Pandemic-Related Fraud Update.
- Customer / Member Due Diligence – The Program and The Process;
- “High-Risk” Products, Services, and Geographies;
- Institutional Risk Assessments;
- Suspicious Transactions, Terrorist Financing, and other Money Laundering Techniques;
- Suspicious Activity Reporting (SAR) – FinCEN Form 111;
- Environmental Crimes, Ransomware, Online Child Sexual Exploitation (OCSE) Crimes, Human Trafficking and Human Smuggling, Elder/Vulnerable Adult Exploitation, Convertible Virtual Currency (CVC), Cyber- Events and Cyber-Related Crimes, and Disaster-Related Fraud;
- Money Services Businesses (MSBs), Hemp-Related Enterprises (HREs) and Marijuana-Related Enterprises (MREs), Third-Party Payment Processors (TPPPs), Real-Estate Geographic Targeting Orders, “De-risking”, and Other High-Risk Clients and Entities;
- Federal BSA/AML Examination – Latest Updates