Bank Secrecy Act Compliance Two-Day School
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Printed Item No: M-BS2
Electronic Item No: EM-BS2
A manual designed to encompass the broad range of topics included in the realm of the Bank Secrecy Act and Anti-Money Laundering.
- Designing and Implementing a BSA Program
- Establishing the Appropriate Culture of Compliance
- 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 Clients
- Overview of Regulatory and Statutory Components of BSA
- Customer/Member Identification and Other Title II Programs
- Completing the Currency Transaction Report (FinCEN Form 112)
- Exempting Eligible Clients from CTR FIling (FinCEN Form 110)
- BSA Survey Results and Findings
- How OFAC Fits the Process – the New Sanctions Compliance Program (SCP) Framework
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 recordkeeping 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.
DAY ONE – The “Basics”
- Statutory and Regulatory Requirements
- Enforcement Actions, MRIAs and the “Lessons Learned”
- Acronym Review and Sources of Information
- Federal BSA/AML Examination – Latest Updates
- USA PATRIOT Act Requirements and Implications
- Currency Transaction Reporting – Updated FinCEN Form 112
- Exemption “Opportunities” From CTR Reporting
- Recordkeeping Requirements
- Office of Foreign Assets Control (OFAC) Sanctions Compliance Program (SCP) Framework
- Culture of Compliance
- BSA Survey Results
DAY TWO – “Advanced”
- 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
- SAR “Confidentiality”, Growth and Cultivation of Hemp, Elder / Vulnerable Adult Exploitation, Tax Refund Fraud, Marijuana-Related Businesses, Human Trafficking and Human Smuggling, Business E-Mail Compromise Fraud, Fentanyl and Synthetic Opioids, Convertible Virtual Currency (CVC), Cyber- Events and Cyber-Related Crime, and Disaster-Related Fraud
- Money Services Businesses (MSBs), Third-Party Payment Processors (TPPPs), Real-Estate Geographic Targeting Orders, “De-risking”, and Other High-Risk Clients and Entities
This manual assists financial institutions in meeting the annual training requirements imposed by the BSA regulations and provides attendees with the opportunity to network with other professionals interested in BSA compliance.