BSA/AML Top Gun Conference
March 2 - 3, 2021All times are relative to
EASTERN Standard Time
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.
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.
FinCEN COVID Advisories
FinCEN published a series of advisories relating to emerging fraud trends that arose during the pandemic. We are going to take an in-depth look at each in some rapid-fire 30-minute sessions. Each session will highlight the background of the various schemes, identify applicable red flags that business lines should consider when interacting with customers, and provide SAR-filing instructions each scenario.
COVID and Medical Services Fraud
Imposter and Money Mule Schemes
COVID and Cybercrime
Payment Protection Program Loan Fraud
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, Ransomware and the Travel Rule
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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