What Happened Since Last Year?
FinCEN finally published a proposed rule relating to the AML/CFT Priorities. The industry continues to wait for updated customer due diligence rules as we collect beneficial ownership information. Meanwhile, we saw several alerts relating to terrorist financing due to violence in the Middle East and a rise in check and virtual currency fraud. In this introductory session, we will provide relevant information you need to identify where the emerging trends and risks are in AML/CFT.

Suspicious Activity Referrals
One of the challenges many AML/CFT Officers face is that they need cooperation from other business lines to monitor and identify suspicious activity throughout a complex organization. Monitoring reports and software is helpful, but those who have direct contact with customers are often in a better position to identify body language, behavior or customer statements that may indicate that something is suspicious. We'll cover best practices for encouraging quality staff referrals and how to communicate responsibilities to the various business lines within your institution.

The Evolving Role of AI in Suspicious Activity Monitoring
More and more vendors are jumping into the AI space to offer suspicious activity monitoring solutions to better manage risk and improve efficiency. There is great potential for enhanced monitoring of customer behavior, but also the risk of utilizing new innovations. Now may or may not be the time for your institution to make changes to how you monitor for suspicious activity, but knowledge of what is available can help you plan for the future when discussing strategy with your board and executive management team.

Quantifying AML/CFT Priorities Risk
FinCEN's proposed rule requires that financial institutions incorporate AML/CFT Priorities into their AML Risk Assessment. Financial institutions have always had an expectation that they analyze both qualitative and quantitative risk as part of the assessment. Quantifying the number of accounts or customers or the volume of transactions is a straightforward process, but how do we quantify risk of government corruption? We'll cover how to leverage your existing understanding of AML risk as well as data that you're already collecting to help you evaluate these new risk factors.

Status of the Corporate Transparency Act
With the US District Court of Eastern Texas issuing an injunction blocking enforcement of the Corporate Transparency Act for reporting companies to submit their beneficial ownership information by January 1, 2025, what does this mean for financial institutions? FinCEN had originally planned to issue revisions to the 2018 Customer Due Diligence Rules as the timeframe for financial institutions to access the beneficial ownership secure site draws near. Now we sit in limbo waiting for appeals to take their course, and FinCEN to decide what the landscape of customer due diligence should look like. We'll give you the most recent updates on what is happening to this legislation.

Breaking down the TD Bank Penalty
$3 billion in penalties should get everyone's attention. It certainly raises questions about what went wrong with TD Bank's compliance culture. There were breakdowns at every level of the organization that permitted millions of dollars in drug money to be laundered through the bank. We will sift through the published fines and enforcement actions and some media reports to break down what happened and what we can learn from it to manage our own institutions' risk.

Applying Third-Party Risk Management to AML Risk Management
The prudential regulators issued Joint Agency Guidance on Third-Party Risk Management. While on the surface, this may seem to only apply to vendor management, it has far-reaching implications that can cross over into AML Risk Management. As we have seen from the numerous enforcement actions levied against institutions engaging in banking as a service with third-party finTechs, there is additional risk that must be considered when a third party is delivering products and services to their customers or using the bank as a conduit. In either case, we have responsibilities for managing and overseeing these relationships to ensure that they comply with the bank's AML policy and procedures. In this session we will consider best practices for managing AML risk with our third parties.

Managing Monitoring Parameters and Model Risk
All regulators have issued joint guidance on model risk management. The challenge is to apply this guidance to our institution's monitoring software when parameters may be established by our vendor and the institution lacks the requisite knowledge for tuning and testing the system's output. However, the guidance recommends that system parameters be evaluated annually. This doesn't mandate that parameters be changed when the institution's risk profile hasn't changed, but there is an expectation the bank document analysis of the suspicious activity monitoring model. Examiners criticize institutions that use default settings as they have not been tailored to your institution's unique risk profile.

Fraud & Forensic Accounting for the Non-Accountant
One of the AML/CFT Priorities is fraud, which covers a wide range of activity that FinCEN identifies through many advisories. Check fraud, online banking fraud, elder abuse, embezzlement, loan fraud, tax fraud, etc. While FinCEN provides red flags in each of its advisories to aid us in identifying fraud patterns, since AML professionals are not accountants, it can be difficult for us to understand certain types of fraud. For example, due diligence of a higher risk customer often includes requesting financials to see if the information mirrors deposit activity, but if we're not a CPA, we may lack the knowledge to interpret the very documents we are collecting. This session will give you some tools for evaluating financial documents and account history through the lens of financial accounting to aid in analyzing activity.

FinCEN's Proposed Rulemaking - AML Risk Assessment
This session complements the gathering of quantitative data for the AML/CFT Priorities. Once we have the data, what do we do with it? The proposed rule does not provide a structure for crafting an AML Risk Assessment or implementing the AML/CFT Priorities in your existing methodology. We'll discuss various methodologies for AML Risk Assessment and consider a few possible ways to incorporate the new risk factors into your 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 questions@bolconferences.com. We will tackle as many topics as possible in the alloted time. 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.