BSA/AML Top Gun Conference
March 2 - 3, 2021
All times are relative to EASTERN Standard Time
March 2
10:00 - 11:00 What Happened Since Last Year?
Brian Crow
11:00 - 12:00 Risk-based BSA/AML Program
Robin Guthridge
12:00 - 12:15BREAK
12:15 - 1:00 Enhanced Due Diligence: Moving away from the checklist
Victor Cardona
1:00 - 1:45 Virtual Currency: Exchanges Masquerading as Users
Brian Crow
1:45 - 2:30 LUNCH
2:30 - 3:30 Suspicious Activity Monitoring in a Pandemic
Deborah Crawford
3:30 - 4:30 CTR Updates, Pending, Final and Everything in between -
John Burnett
4:30 - 4:45 BREAK
4:45 - 5:30 Managing Remote audits/exam in a pandemic environment
Brian Crow
5:30 - 6:00 Q and A
6:00 Adjourn
March 3
10:00 - 10:50Managing Cannabis Risk
Robin Guthridge
10:50 - 11:50 Account opening during a pandemic
Deborah Crawford
11:50 - 12:15 BREAK
12:15 - 12:45 COVID and Medical Service Fraud
Victor Cardona
12:45 - 1:15Imposter and Money Mule Schemes
Victor Cardona
1:15 - 1:45 COVID and Cybercrime
Victor Cardona
1:45 - 2:15 Payment Protection Program Loan Fraud
Victor Cardona
2:15 - 3:00 LUNCH
3:00 - 3:30AMLA Act of 2020
Robin Guthridge
3:30 - 4:30OFAC: Constructing a Compliance Program
4:30 - 4:45BREAK
4:45 - 5:30 BSA Pepper
5:30 - 6:00 Q and A
6:00 Adjourn
Here's a list of topics we are working on for TOP GUN 21. Because we endeavor to offer the most timely and relevant topics, the topics posted here are subject to change. If any changes are made, this page will be updated to reflect the modifications.
What Happened Since Last Year?
Perhaps a better question is "What didn't happen last year?" This introductory session will cover suspicious activity trends during the pandemic, recent enforcement actions, FinCEN advisories, SAR disclosures, and BSA hot topics that made the headlines.

Managing Cannabis Risk
FinCEN provided additional guidance to provide banking services to hemp related businesses. However, there have been no updates relating to marijuana, CBD Oil and other cannabis derived products or for businesses that indirectly provide services to the cannabis industry. As the number of states with some form of legalized cannabis product grows, the need to align your policy and procedures with your board's appetite for risk grows. In this session we will provide an overview of a cannabis risk program and demonstrate how to align it with current guidance.

Building an OFAC Compliance Program
Although the basic framework of OFAC has not changed much in recent years, product delivery methods, virtual currency and an increase in the number and types of sanctions has. It's time to dust off your OFAC Program to make sure it is still current. In this session, we discuss the requirements for building a compliance OFAC Program from the ground up: risk assessment, to policy, to procedures to managing OFAC alerts and managing monitoring software. We will consider the variables of OFAC risk and their impact of your Program. We will cover processes for blocking and rejecting transactions, including when the potential match lacks all information needed to make a determination. Finally, we will review recent OFAC Enforcement Action to better understand what can go wrong with your Program.

Managing remote audits/exams in a pandemic environment
Although the pandemic has altered many of our routines, regulators continue to conduct periodic examinations and the requirement for independent oversight of the BSA Program remains. Managing the process while rotating staff at the office or working from home presents some unfamiliar challenges. In this session we will explore steps prior to, during and after the audit/exam to aid in having a successful engagement.

AMLA Act of 2020
The Anti-Money Laundering Act of 2020 will make significant changes to the BSA/AML landscape. This is the most substantial anti-money laundering and counter terrorism legislative reform since the implementation of the USA Patriot Act of 2001. We will discuss the major provisions of the Act, and the effect they will have on the U.S. banking system.

Suspicious Activity Monitoring in a Pandemic
What's the New Normal? During this session we will talk about the factors that may have affected your transaction monitoring. Your customer's new normal could be affecting existing baselines and cause you difficulties in figuring out when they are over and under normal transactions. We will talk about movements from cash to electronics, person to person payments, virtual currency and more. Normal is not just a dryer setting, it's your customers business profile. We may have new baselines to consider for pandemic purposes.

COVID and Medical Services Fraud
COVID-related medical services fraud covers many schemes, including fraudulent cures, tests, vaccines, and services; non-delivery scams; and price gouging and hoarding of medical-related items, such as face masks and hand sanitizer. FIN-2020-A002 covers these schemes, along red flag indicators and SAR filing requirements.

Imposter and Money Mule Schemes
The COVID-19 pandemic has resulted in an increase in consumer fraud. Imposter scams and money mule schemes, where criminals deceive victims by impersonating federal government agencies, international organizations, or charities all fall under consumer fraud. FinCEN Advisory FIN-2020-A003 addresses the red flag indicators and SAR filing requirements.

COVID and Cybercrime
Criminals are increasingly exploiting the COVID-19 pandemic in cyber-enabled crime through malware and phishing schemes, extortion, business email compromise (BEC) fraud, and exploitation of remote applications, especially against financial and healthcare systems. All aspects of FinCEN Advisory FIN-2020-A005 will be covered to highlight the increasing Cybercrime aspect due to the COVID-19 pandemic. Red flag indicators and SAR filing requirements will be shared with case examples.

Payment Protection Program Loan Fraud
With the second round of the PPP loan program underway, what are the characteristics financial institutions should be looking for from a BSA-perspective? Beyond the PPP program, other SBA loan programs will be highlighted, such as the Economic Injury Disaster Loans (EIDL) and the Shuttered Venue Operators (SVO) grant program. A case example will also be shared to show the reach of PPP fraud with multiple law enforcement agencies.

CTR Updates, Pending, Final and everything in between
FinCEN made several changes to the CTR Filing instructions in the last year to make the report more useful to law enforcement. The changes increase transparency in persons' roles in the transaction, but also mean additional filing requirements for us. To further cloud matters, compliance for some of the new rules is mandatory, while others have been suspended due to the pandemic. This session will walk you through all of the new requirements, noting which are effective and which are delayed and provide examples of how to comply with the new instructions.

Account opening during a pandemic
The pandemic has resulted in lobbies being closed or reduced to in-person by appointment only. Many institutions encourage use of technology as an alternative to encourage social distancing. This may include online applications and/or online account opening. For institutions that have not previously offered these options, ensuring that new processes comply with Customer Identification Program and Bank Secrecy Act requirements is a critical piece of offering this service delivery option to our clients.

Virtual Currency: Exchanges Masquerading as Users
Virtual Currency continues to emerge as a hot button for BSA/OFAC risk. FinCEN and the U.S. Treasury published joint advisories regarding the risk of virtual currency money transmissions being used to funnel funds to sanctioned persons. While your customer may not be a virtual currency transmitter, they could be a victim of data breach which leads them to send virtual currency to the fraudsters. In this session we will explore your monitoring and SAR-filing responsibilities relating to virtual currency transactions.

Enhanced Due Diligence: Moving away from the checklist
FinCEN published guidance relating to collecting enhanced due diligence for politically exposed persons and non-government organizations. On the one hand, these documents serve as a guide for what types of questions to ask these customers. However, we can't stop our review just because we receive the answers. All EDD guidance urges a risk-based approach to the information we collect. These documents should serve as a guide for collecting pieces of the EDD puzzle for certain customer types. Collection of this information does not guarantee compliance. We still must put the pieces of the puzzle together to tell a story about our customer to document our understanding of the relationship.

Risk-based BSA/AML Program
"What does BSA require of your Program" vs. "What is a good idea to do for your Program?" If we had unlimited resources, we may not care how much time, energy and money is used to comply with BSA. However, the reality is that we don't monitor every customer and every transaction. Recent guidance indicates that examiners are taking a risk-based approach and we are encouraged to do the same. Before we take this as carte blanche to start cutting back on our processes, this session will help identify relevant risk factors we should consider and how that translates to policy and procedures.

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