BSA/AML Top Gun Conference
March 8 - 9, 2022

Current Topics to be Addressed during the 2022 Top Gun Conference

Conference begins each day at the specified time which is dependent on which time-zone you reside in.

 10:00am - 6:00pm Eastern Time
   9:00am - 5:00pm Central Time
   8:00am - 4:00pm Mountain Time
   7:00am - 3:00pm Pacific Time

March 8
9:00 - 10:00 What Happened Since Last Year?
Brian Crow
10:00 - 11:00 Insider Abuse Monitoring and Reporting
Robin Guthridge
11:00 - 11:15BREAK
11:15 - 12:15 SAR Completion
Deborah Crawford
12:15 - 1:15 Suspicious Activity Monitoring Priorities Part I
Victor Cardona
1:15 - 2:00 LUNCH
2:00 - 3:00 Suspicious Activity Monitoring Priorities Part II
Victor Cardona
3:00 - 3:45 Money laundering and big-ticket industries
Brian Crow
3:45 - 4:00 BREAK
4:00 - 4:30 Voluntary Information Sharing: Facts vs. Myths
John Burnett
4:30 - 5:00 Q and A
5:00 Adjourn
March 9
9:00 - 10:00Derisking Customers
Deborah Crawford
10:00 - 11:00 What Qualifies as a Cyber Event?
Brian Crow
11:00 - 11:15 BREAK
11:15 - 12:15 Banking the Cannabis Industry
Robin Guthridge
12:15 - 1:15Building a Training Program
Deborah Crawford
1:15 - 2:00 LUNCH
2:00 - 2:45 Building a Monitoring Program
Brian Crow
2:45 - 3:15 AMLA Act Update: What has FinCEN been up to?
Brian Crow
3:15 - 3:30 BREAK
3:30 - 4:15BSA Pepper
4:15 - 5:00Q and A
SAR Completion - Deborah Crawford
Here a checkbox, there a checkbox, everywhere a checkbox! The Suspicious Activity Report is one of the most complex documents we must complete. Nuances abound in the various types of suspicious activity we are expected to report, and the types of products and instruments involved in the suspicious activity. In this session we will walk you through the report line by line to help you make sure nothing gets missed when you are filing your reports.

What Happened Since Last Year? - Brian Crow
It was another busy year for FinCEN due to the passage of the Anti-Money Laundering Act in December 2020 and another year of growing electronic crime due to the continuation of COVID. We'll bring you up to speed on current happenings in the Bank Secrecy Act, recent enforcement actions, and changes that may be on the horizon.

De-risking customers - Deborah Crawford
When evaluating customer risk, compliance risk, financial risk, and legal risk are often the first that come to mind. However, reputation risk is quickly catching up. The decision to provide banking services to a particular individual or industry could be impacted by a desire to avoid affiliation with "social hot buttons" such as cannabis or adult entertainment. In this session we will discuss how to evaluate and document our risk tolerances and what steps we should take to mitigate risk.

Building a Training Program - Deborah Crawford
Many institutions take a "checkbox" approach to BSA training. Assign everyone an online BSA course and we're good for another year, right? The regulatory requirements are that each employee receive job specific BSA training that includes general BSA knowledge and institution specific policy and procedures. Simply checking a box does not address this requirement. In this session we will cover the steps you should consider to build a comprehensive training program for new and current employees, the BSA Department and your board to ensure everyone has the knowledge they need for a successful BSA Program.

Suspicious Activity Priorities and Red Flag Monitoring (Parts I and II) - Victor Cardona
One of the requirements of the Anti-Money Laundering Act was for FinCEN to publish AML priorities to highlight the types of crimes it sees as presenting the greatest risk to the United States. FinCEN published a list of eight priorities on June 30, 2021. They include corruption, cybercrime, terrorist financing, fraud, transnational criminal organization activity, drug trafficking organization activity, human trafficking and human smuggling, and proliferation financing. While this publication did not create any new rules for our BSA Programs, we should be mindful of these types of activities should they occur through our institution. In this two-part session, we will cover four of the eight priorities in each and discuss red flags you should consider in your monitoring to determine if this activity is taking place.

Insider Abuse Monitoring and Reporting - Robin Guthridge
One of the most delicate types of investigations we must conduct is in suspected cases of insider abuse. On one hand we want to protect the institution and its customers from loss and on the other, not tip off the insider that we suspect something is wrong until we complete our investigation. Matters can be further complicated if the insider is a board member or high-level executive who would normally receive updates of SARs. This session will provide suggestions and processes for managing internal investigations and SAR reporting.

What Qualifies as a Cyber Event? - Brian Crow
Cyber Events are one of FinCEN's eight AML Priorities. However, many BSA Professionals have limited IT backgrounds and struggle to know when a Cyber Event SAR is needed or how to complete one. In this session, we will consider FinCEN's cyber event guidance and explore several scenarios to help you understand when SARs are required and how they should be completed. We'll also define some of the more complex cyber lingo to help guide you along the way.

Banking the Cannabis Industry - Robin Guthridge
As prevalent as the cannabis industry has become in states where it is legal in some form, it is likely not a matter of "if" you're banking it, but "how much" and "do you know" that you are banking it. In absence of any guidance since 2014 on marijuana and 2020 on hemp, cannabis continues to present risk and treacherous terrain for the financial industry. In this session we will cover the status of federal legislation and best practices for due diligence and ongoing monitoring.

ML & Big Ticket Industries - Brian Crow
FinCEN has published several advisories relating to transactions that are higher risk for money laundering through big ticket industries. New rules proposing that some of these industries develop AML Programs. What does this mean for your BSA Program? There may be additional due diligence requirements. Risk rating methodologies may need to be evaluated. Finally, there may be additional red flags to consider. In the session we will explore these industries and help you understand the flow of funds.

Voluntary Info Sharing - John Burnett
One of the consistent messages to come from FinCEN in the last few years is the importance of utilizing voluntary information sharing to assist in suspicious activity investigations. A common question in the BOL discussion threads is, "Should I file a SAR." Having as many pieces to the puzzle as possible helps in the SAR decision making process. In this session we will discuss the permissible circumstances for sharing information and dispel common myths about the process.

Building a Monitoring Program - Brian Crow
One of the five BSA Pillars is the BSA Program which consists of all the written policies and procedures that establish internal controls to ensure compliance with the BSA requirements. How do we know if our Program is effective? Waiting every 12-18 months for an independent audit or exam could leave us with significant look backs if a key process was overlooked for a long period of time. Part of an effective BSA Program is periodic internal monitoring of key processes. In the session we will cover the who, when, how, and why of a strong monitoring program.

AML Update - Brian Crow
We're "anxiously" waiting for new regulations from FinCEN to implement the AMLA Act. So far there have been proposed rules on beneficial ownership, a lot of speeches, and some requests for information. What does this all mean? Where is the BSA heading and what does it mean to our Program? In this session we will unpack what FinCEN has told us so far and discuss the potential implications for what lies ahead.

BSA Pepper
BSA Pepper In this lightning round, our entire panel discusses a wide range of key topics that don't individually require a lot of time but are nonetheless important.

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