BSA/AML Top Gun Conference
March 11 - 12, 2024
All times are relative to EASTERN Daylight Saving Time

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 11
10:00 - 10:50 What Happened Since Last Year?
Brian Crow
10:50 - 11:00 BREAK
11:00 - 11:30 Corporate Transparency Act Update
John Burnett
11:30 - 12:15Best Practices for Board Training
Adam Witmer
12:15 - 12:30 BREAK
12:30 - 1:30 The Evolution of Artificial Intelligence and Suspicious Activity Monitoring
Robin Guthridge
1:30 - 2:30 LUNCH
2:30 - 3:00 Digital Currency Update
Brian Crow
3:00 - 3:50 From Start to Finish: Overhauling Your Risk Model
Victor Cardona
3:50 - 4:00 BREAK
4:00 - 4:50 Managing Higher Risk Customers
Robin Guthridge
4:50 - 5:00 BREAK
5:00 - 6:00 Q and A
6:00 Adjourn
March 12
10:00 - 10:50 SAR Decision Making
Brian Crow
10:50 - 11:00 BREAK
11:00 - 11:50 Keeping up with FinCEN SAR Typologies
Victor Cardona
11:50 - 12:00 BREAK
12:00 - 12:50 FATF: Abuse of Non-Profit Organizations
Adam Witmer
12:50 -12:55 BREAK
12:55 - 1:30 Geographic Targeting Orders and AML for Real Estate
John Burnett
1:30 - 2:30 LUNCH
2:30 - 3:30Upgrading Your Risk Assessment
Robin Guthridge
3:30 - 3:45 BREAK
3:45 - 4:45BSA Pepper
4:45 - 5:00BREAK
5:00 - 6:00 Q and A
6:00 Adjourn
What Happened Since Last Year?
FinCEN spent much of 2023 continuing to publish notices and advisories to keep the industry updated on evolving suspicious activity and fraud trends. This did not translate to significant rulemaking except for finalizing small business requirements for the Corporate Transparency Act. As the conference date approaches, we will continue to monitor FinCEN's activities to bring you the most current happenings in the Bank Secrecy Act and make sure you have the map for the road ahead. This session will consider BSA hot topics and trends as well as recent enforcement actions to help you know where the risk to your Program may lie.

Corporate Transparency Act Update
FinCEN finalized two of its three stages of rulemaking to implement the Corporate Transparency Act. These rules have created more questions than answers for the financial industry. There are now differences between what information FinCEN is going to collect using the Beneficial Ownership Secure System (BOSS) and what financial institutions are collecting at account opening. In this session, we will dissect the requirements and discuss what this means for your institution in the coming year.

Best Practices for Board Training
Presenting AML/CFT Training to the Board of Directors can be an intimidating and daunting task. We have knowledge of regulatory requirements that can fill volumes, and we have five minutes to tell the Board all about it. What does the Board really need to know to fulfill their fiduciary duty? In this session we will discuss what and how to communicate efficiently and effectively to our Board and provide materials that our examiners can review to see that the Board received adequate training to comply with the Pillar.

The Evolution of Artificial Intelligence
A concept that is likely abstract to many is becoming a reality. The increased use of Artificial Intelligence (AI) in many industries including the financial sector as well as by criminal enterprises will eventually impact the landscape of AML/CFT Compliance. Many automated monitoring vendors are evaluating how to incorporate AI into their product offerings. There are many unanswered questions at this stage. "Will AI be cost effective?" "How can we validate the AI's effectiveness under current guidance?" In this session we will explore the concept of AI and its current and potential future impact on our industry.

Digital Currency Update
Last year FTX grabbed all the headlines. This year we continue to see regulatory enforcement in the digital currency space. Even if your institution has chosen not to provide services to the digital currency industry, its reach continues to grow and still could impact your institution. In this session we'll explore the headlines, positive and negative, and discuss best practices for managing risk.

From Start to Finish: Overhauling Your Risk Model
Customers complete a questionnaire at account opening and a manual or automated process determines a risk rating. We're done with that step, right? The "ongoing monitoring" requirement of the Customer Due Diligence Pillar notes that developing an initial risk profile is the first step in the process, but not the only step. Our assessment of customer risk must evolve as the customer risk changes. Also, our risk model must evolve as we develop new products and services or onboard different customer types. In this session we will consider the evolution of customer risk and provide tips for evaluating your risk model.

Managing Higher Risk Customers
While most financial institutions have created robust policies and procedures related to managing their high-risk customers based on guidance from the examination manual and other publications, it can still be a struggle developing processes for those higher-risk customers that do not have specific mandates for what information we should collect. Also processes for identifying higher-risk customers after account opening or establishing a process for changing risk rating may be lacking. There is minimal regulatory guidance for customers not identified in the exam manual. In the session we will consider high-risk customers that you may be providing services to but have slipped through the cracks of your risk-rating and monitoring processes.

SAR Decision Making
One of the most frequent questions in the BankersOnline discussion threads is "Should I file a SAR for...?" Our system may flag transactions, but they only tell a fraction of the story. In this session we will walk through several scenarios beginning with transactions that led to a SAR investigation, the steps and information that we may need to consider to help piece together what is happening, and how to document our analysis of the investigation to support the conclusion.

Keeping Up with FinCEN's SAR Typologies
One of the ways that FinCEN utilizes SAR data, (besides the obvious of identifying suspicious activity for law enforcement) is to track patterns of suspicious activity. The "Filing Note to FinCEN" provides an opportunity to connect a SAR to a particular advisory or notice for specific types of activity that FinCEN has identified as a concern. In this session, we will discuss recently published typologies, red flags to help you identify the patterns of activity, and the SAR filing instructions that accompany them.

Financial Action Task Force: Abuse of Non-Profit Organizations
With the rise of violence in the Middle East, renewed attention is being given to terrorist financing through non-profit organizations. While not every non-profit presents the same amount of risk, the Financial Action Task Force (FATF) published 100 pages on the topic in November 2023. With this again emerging as a potential threat, anticipate examiners to evaluate your due diligence processes and monitoring of this industry. In this session we will help summarize FATF's findings and recommendations and help you evaluate your due diligence processes for non-profits.

Geographic Targeting Orders and AML for Real Estate
FinCEN extended and expanded Geographic Targeting Orders relating to non-financed purchases of real estate. Mortgage companies are already required to have AML Programs. Is more rulemaking and expanded oversight on the horizon for the real estate industry? In this session we will discuss the implications this rulemaking could have for your due diligence for customers in the real estate industry.

Upgrading Your Risk Assessment
If you're still using Appendix J of the FFIEC Manual as your risk assessment, it's time to upgrade or face regulatory scrutiny. As customers, products, services, and technologies have evolved, so should your risk assessment. This "living" document should tell the story of the risk profile of your institution. In this session we will cover the risk factors that you should consider, how to quantify and analyze those risks, and how to evaluate the strength of your controls. The FFEIC Manual removed the 12-18 month update requirement. How frequently must we update our risk assessment?

BSA Pepper Our panel will handle those rapid-fire topics that didn't get their own session. Participants are encouraged to send in topic requests in advance to We will tackle as many topics as possible as time permits. The interaction of our BSA/AML experts provides great insight into the perspectives and multiple strategies that can be employed in BSA/AML Compliance What is the value of the BSA Pepper Session? We can cover more topics that don't require a 30-60 minute stand alone presentation, but still give you the nuanced tidbits of information that make Top Gun the best source of BSA Compliance Information

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