Tentative Agenda*
BSA/AML Top Gun Conference
February 27 - 28, 2018
All times are relative to Mountain Standard Time in Scottsdale, Arizona.
February 27
7:30 - 8:00 Registration
8:00 - 9:00 Remarks from FinCEN
Betsy Maesen, FinCEN
9:00 - 10:00 What Happened Since Last Year?
Brian Crow
10:00 - 10:15BREAK
10:15 - 11:30 Countering the Financing of Terrorism
John Geiringer
11:30 - 12:30 LUNCH
12:30 - 1:00 Privately Owned ATM: Requirements vs. Suggestions
Brian Crow
1:00 - 1:45 Building a Client Risk Rating Framework
Victor Cardona
1:45 - 2:15 Exam Trends, Management and Common Findings
Brian Crow
2:15 - 2:30 BREAK
2:30 - 3:30 Managing BSA Third Party Risk
Brian Crow and Victor Cardona
3:30 - 4:00 Q and A
4:00 Adjourn

February 28
8:00 - 9:00Layers of Ownership
Mary Beth Guard
9:00 - 9:45 The Beneficial Ownership Requirement - Tying up Loose Ends
John Burnett
9:45 - 10:00 BREAK
10:00 - 12:00 "Real World" Money Laundering
The Ronin Resources Group
12:00 - 12:15Q and A
12:15 - 1:00 LUNCH
1:00 - 2:00 How to train your frontline
Mary Beth Guard and Brian Crow
2:00 - 2:30 BSA Pepper
Mary Beth Guard, John Burnett, Victor Cardona and Brian Crow
2:30 - 2:45BREAK
2:45 - 3:30SAR Naratives. How to catch the eye of law enforcement
Victor Cardona
3:30 - 4:00Q and A
Here's a list of sessions we're working on for the 2018 BSA/AML Top Gun Conference.

Remarks from FinCEN
We are pleased to welcome Betsy Maesen from FinCEN again this year. Betsy has previously been the featured public relations speaker on behalf of FinCEN and she provides valuable perspective from the regulatory agency on current trends and hot topics in the Bank Secrecy Act. Take advantage of this opportunity to submit questions direct to the BSA rulemaking authority.

What Happened Since Last Year?
The last year in Bank Secrecy Act featured some of the lesser discussed BSA topics including Special Measures and Geographic Targeting Orders. Virtual Currency made a return to the conversation as exchangers faced a rise of ransomware payments. These along with civil money penalties and recent enforcement actions will round out this discussion. Stay informed to comply with the pillar requirement that BSA Officer has sufficient knowledge of evolving BSA expectations.

Beneficial Ownership: How to train your frontline
As the BSA subject matter expert for the bank, the BSA Officer is already tasked with understanding the new customer due diligence and beneficial ownership rule. Besides managing the implementation plan, many BSA Officers will also be tasked with training the affected departments. How much training does each department need? When should it be completed? What questions should we plan to answer? This session will discuss strategies for communicating the new rule to various business lines including retail, commercial, mortgage, and operations.

Countering the Financing of Terrorism
In this session, John Geiringer will address the evolving challenge of terrorism financing and describe the tools available to the U.S. government, the international community, and the private sector to combat this problem. He will offer practical advice about how anti-money laundering professionals can maximize their impact in the fight against terrorism, and minimize the overall risk to their organizations. John is a banking attorney who formerly chaired the BSA/AML Subcommittee of the American Bar Association's Banking Law Committee.

Exam Trends, Management and Common Findings
It's no surprise that BSA will be covered at our next Safety and Soundness Exam, but sometimes surprises can occur during the exam. Exam preparation and management isn't covered in the FFIEC Examination Manual, but advance knowledge of what to expect, how to respond to the unexpected question and even how to respectfully disagree with an examiner can be the difference between a satisfactory and a Matter Requiring Attention or Memorandum of Understanding. We'll discuss some do's and don'ts of managing the exam process as well as current trends in enforcement.

Managing BSA Third Party Risk
There are many third parties that may touch our BSA Program. Whether it is an outsourced audit solution, an automated monitoring program or third-party review of transaction activity, the BSA Officer is ultimately responsible for ensuring the Program is compliant. Examiners expect that these relationships are appropriately managed. This session will provide discussions of current regulatory guidance and expectations for third party risk management as it relates to the Bank Secrecy Act.

"Real World" Money Laundering: The Problem of Missed Red Flags and How to Avoid Them
How many crimes have been followed by a commentary, "If we had only seen the signs?" A common frustration for many BSA Officers is that we are told to watch out for this crime pattern or that crime pattern, but often our knowledge and experience may be insufficient to identify the pattern of activity that points to a specific crime. After specifics come to light during an exam, banks may face costly lookback projects. The new normal in BSA enforcement is what "the bank knew or should have known." This discussion will include real life case studies led by former law enforcement officers to help the BSA Officer ensure alerts and core reports are appropriately reviewed and evaluate the effectiveness of the Bank's monitoring program.

Privately Owned ATMs: Requirements vs. Suggestions
Privately Owned ATMs can be a conduit for introducing cash into the banking system and customers who operate them are considered a higher-risk person in the Exam Manual. However, not all ATMs are created equal and consequently, the risk mitigation strategies should also be appropriately risk based. Auditors and examiners both make recommendations about due diligence methods for managing these relationships. How much is enough? What does the regulation actually require? This session will cover identification, due diligence, monitoring and risk mitigation strategies for this customer type.

The Beneficial Ownership requirement -- Tying up loose ends
A short discussion of FinCEN's beneficial ownership requirements for legal entity customers. The scope of the rule will be discussed, along with the definitions of key terms. We'll also look at the relationship between this rule and CIP requirements, including the key differences between the two rules. Finally, we'll discuss any official light that FinCEN has shed on the beneficial ownership rule since last year's Top Gun gathering.

Building a Client Risk Rating Framework
The FFIEC manual is clear when discussing Customer Due Diligence and the expectations of Enhanced Due Diligence for higher risk clients. However, building a Client Risk Rating (CRR) framework is not outlined, but essential to ongoing monitoring of higher-risk clients, and potentially suspicious activity. What about Low-risk and medium-risk clients? Examiners have started requesting due diligence frameworks for these as well. Building out the CRR framework starts at account inception, continues through periodic re-scanning of risk scores, and ends with BSA triggering events, such as EDD or SAR investigations. Building a CRR framework is unequivocally pivotal in ongoing monitoring for suspicious activity; 5th Pillar tenet.

Layers of Ownership
If the entity you are banking is simply owned by individuals, determining beneficial ownership is a relatively simple task. These days, however, it is not uncommon for an entity to be owned by one or more other entities, which may in turn be owned by other entities. This session prepares you to answer customer questions about how to determine beneficial owners and provides a framework for discerning and documenting who owns what.

SAR Narratives: How to Catch the Eye of Law Enforcement
With thousands of SARs being filed by various financial institutions, how do you get your SAR to pop out from the pile during the SAR Review Task Force 'readings'? This session will cover SAR narratives and best-practices on SAR narrative structure and format, along with narrative substance that may attract law enforcement's attention. Examples of inadequate and adequate SAR narratives will be provided, key terms that law enforcement looks for, along with the Life Cycle of a SAR.

BSA Pepper
In this fast-paced "lightning round," our speakers step up to bat around topics you have told us you want to hear about that aren't encompassed within other segments of the program.

*Because we endeavor to offer the most timely and relevant topics, the agenda posted here is subject to change. If any changes are made, this page will be updated to reflect the modifications.

If there is topic you would like to see, send us an email at
requests@bolconferences.com and tell us ... this is YOUR conference, so please tell us what Y O U want to hear.

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