Some people might think that regulatory attention to the BSA has let up over the past couple of years, given other difficulties and areas of concern, such as fair lending, TRID, HMDA, and UDAP. Think again. With the safety and soundness of the entire industry the focus of news stories every day and many well-publicized enforcement actions, the regulators obviously haven't eased up. These rules are still very close to being the #1 issue facing compliance officers.
In Part 1, we'll discuss the Bank Secrecy Act provisions in general, including program requirements, risk assessments, CTRs, SARs, and the Beneficial Owner provisions, among other things.
We'll also talk about where the risk areas are and where examiners are criticizing institutions. Your comprehensive program must be continually updated, and we'll make sure you have the information you need to meet expectations.
- BSA program requirements, including the 4 (5?) pillars
- Updating your risk profiles, including due diligence responsibilities
- Currency Transaction Reporting hotspots, including exemptions
- Suspicious Activity Reporting - the backbone of an effective BSA program
- Due diligence responsibilities, including Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk customers
- Selling monetary instruments for cash - collecting and retaining information
- Money Services Businesses (MSBs) – a special type of customer
- And more
Who Should Attend:
These rules impact most anyone in your institution who has direct dealings with customers, such as Customer Service Representatives and tellers. But others are impacted as well, like loan officers and others who make important customer-related decisions. Compliance officers, auditors, attorneys, and management too will benefit from this information, as well, as they often are the ones who must draft these complex programs, administer them, and audit them.
Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Managing Director for Treliant Risk Advisors in Washington, DC. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves on the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.
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