AML RightSource Voices: Hot Topics

Today’s edition focuses on AML Hot Topics.  The discussion will include insights into the intersection of AML compliance and the art and antiquities markets, how to ensure your compliance program supports working effectively with charities, the recently published Framework for OFAC Compliance Commitments, updates on sanctions relating to Iran and North Korea, high risk customers, customer due diligence, and the pending AML legislation in the House and the Senate.

Reference material for today's program:

 

Videos:

1) Regulatory Statement on Risk Based AML/BSA Examinations

Rick Small, Executive Vice President, Director Financial Crimes; John Byrne, Vice Chairman; Tim White, Vice President, Business Development and Sanctions; Chuck Taylor, Executive VP, Head of Financial Crimes Advisory

 

Q: Yesterday the bank regulatory agencies issued a Joint Statement on Risk-Focused Bank Secrecy Act/Anti-Money Laundering Supervision, is there anything in the Joint Statement which we haven’t heard before?

 

2) Charity/Financial Sector White Paper

John Byrne, Vice Chairman

Q: Since 9/11 there has been a lot of discussion about the level of risk related to providing services to non-profit organizations (NPOs) or charities.  At the extreme, some FIs have taken the view that all NPOs are high risk customers and have moved to de-risk their customer-bases by terminating services to NPOs. We know that you have been working with the Charity & Security Network to come up with a process for NPOs and FIs to work together to make services available to NPOs.  Can you update our audience on these efforts?

 

 

 

3) High Risk Customers

Chuck Taylor, Executive VP, Head of Financial Crimes Advisory

Q: Beyond the challenges John just discussed relating to NPOs, what are some of the other key issues that FIs face with high risk customers?


 

4) Customer Due Diligence/Beneficial Owner – continuing questions

Rick Small, Executive Vice President, Director Financial Crimes; John Byrne, Vice Chairman

Q: Another challenge for FIs in managing AML risk is dealing with customer due diligence and beneficial ownership.  Can you share with the audience what is happening in this area?
Q: There are several legislative proposals in Congress relating to AML; do any of those proposals deal with the issues Rick just discussed? 

 

 

5) CAATSA

Tim White, Vice President, Business Development and Sanctions

Q: While we are on the subject of legislation, can you give our audience an update on CAATSA and its implications for their sanctions compliance programs?

 

 

6) Issues from Client Interactions: AML System Tuning & Optimization

Chuck Taylor, Executive VP, Head of Financial Crimes Advisory

Through our Financial Crimes Advisory Services we receive questions on a wide range of topics.  One of the areas that is of particular interest is AML system tuning and optimization.  Can you brief our audience on the current thinking in this area?

 

 

7) Recent OFAC Program Framework

Tim White, Vice President, Business Development and Sanctions

Q: OFAC recently issued a program framework for sanction compliance, can you give us the highlights on the new framework?

 

 

8) Antiquities

John Byrne, Vice Chairman

Q: As money launderers expand the vehicles they use to conceal their ill-gotten gains, FIs need to broaden their understanding of these evolving techniques; I know that you have been working with others to understand how art and antiquities are being used to hide illegal funds.  Can you give our audience an update on this emerging area?

 

 

9) Needed Changes to FFIEC Examination Manual: Risk Based Approach Needs to be Clearly Articulated

Rick Small, Executive Vice President, Director Financial Crimes

The first version of the FFIEC’s BSA Examination Manual was released in 2005; since then, the manual has been revised a number of times.  Each update incorporates the latest thinking from the regulators about what an effective (and compliant) AML program looks like.  As a an expert practitioner, are there some areas of the manual that you think still need updating?

 

 

10) Iranian, DPRK & Venezuelan Evasion Typologies

Tim White, Vice President, Business Development and Sanctions

Q: There has been a lot of activity from the President and the Treasury Department regarding sanctions on Iran, North Korea and Venezuela; can you walk our audience through some basic topologies for each of these sanction programs so they can know what to watch for in their institutions?

 

 

11) Needed Changes to FFIEC Examination Manual: Make Clear that Guidance is not Regulation; Supervisory Actions Should Not Be Based on Examination Manual

Rick Small, Executive Vice President, Director Financial Crimes

Q: We spoke about one area of the FFIEC BSA Examination Manual that needs clarification; is there another topic concerning the manual that you think should be changed?

 

 

12) Issues from Client Interactions: Model Validation

Chuck Taylor, Executive VP, Head of Financial Crimes Advisory

Q: Earlier we discussed a topic raised by our clients; I know that a number of clients have made inquiries about how to handle the model validation process relating to their AML monitoring systems.  What general insight can you give the audience on this topic?

 

 

13) Congressional delisting of EN+Rusal

Tim White, Vice President, Business Development and Sanctions

Q: Recently Treasury lifted proposed sanctions against EN+ and its US subsidiary RUSAL.  What do you see as the significance of this and what does it tell us about how our audience should be handling their sanction compliance programs?

 

 

14) Issues from Client Interactions: FinTech Fraud

Chuck Taylor, Executive VP, Head of Financial Crimes Advisory

Q: We have discussed several topics raised by our clients; with the expansion of FinTech vendors I know that you have been receiving questions about FinTech fraud.  What general insight can you give the audience on this topic?

 

 

15) Increased use of Sectoral Sanctions and the Threat of Secondary Sanctions

Tim White, Vice President, Business Development and Sanctions

Q: With the increased use of sectoral sanctions, can you brief our audience on the impact for them and on the potential impact of some of the threatened secondary sanctions?

 

 

16) Update on House and Senate Legislation

John Byrne, Vice Chairman

Q: Both the House and the Senate are considering bills to update the BSA.  Can you give us the current status of those bills and what they may mean for our audience?

 

 

17)Audience Questions

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