2024 BSA/AML 2-Day School Attendee Portal
Session Dates, Times and Location
March 26 – 27, 2024 | 9:00 am – 4:00 pm
Virginia Bankers Association
4490 Cox Road
Glen Allen, VA 23060
Hotel Information
Hampton Inn Richmond West Innsbrook
10800 W Broad Street
Glen Allen, VA 23060
Agenda
Tuesday, March 26, 2024
9:00 – 10:00 am BSA Updates
In this session we will recap recent FinCEN advisories, guidance, and hot topics. We will also cover recent enforcement actions to analyze what went wrong and where we can expect examiners to focus in the upcoming exam cycle. This will be a great opportunity to catch up on what you should be considering in your Program and how AML/CFT continues to evolve.
10:00 – 10:30 am OFAC Sanctions Updates from Ukraine and Gaza
For many community banks that do not have an international presence, it may seem like conflicts on the other side of the world may not pose much risk. However, bad actors continue to look for weak links in the US financial system to exploit and evade sanctions. Understanding the scope and focus of new sanctions is key to adequately evaluating your risk and ensuring processes are reasonably designed to mitigate those risks.
10:30 – 10:45 am BREAK
10:45 am – 12:00 pm Best Practices for Validating AML and OFAC Monitoring Software
All institutions, even those who use manual processing for suspicious activity monitoring, have a model whether they know it or not. More and more examiners are focusing on the methodologies we employ to manage model risk, whether it be to identify suspicious activity, higher risk customers, or potential OFAC matches. We must be prepared to answer questions like, “How does your system work? and “How did you determine what thresholds to use?” The key to answering these questions is in how you documented decisions you made when implementing software, and how you validated that the decisions you made were reasonable. In this session we will walk through the governance process of managing software and how to ensure its validation complies with regulatory guidance.
12:00 – 1:00 pm LUNCH
1:00 – 1:45 pm Managing FinTech Risk
Regulatory agencies have published updated guidance relating to managing third-party risk, particularly as it relates to FinTechs. Many FinTechs are looking for financial institution partnerships to support their product or service offering. In this session we will consider the types of due diligence that should be considered prior to onboarding a FinTech relationship and over the life of the
1:45 – 2:30 pm SAR Narratives That Catch Law Enforcement’s Eye
Many bankers have the perception that the SARs they spend hours filing wind up in a bureaucratic black hole, never to be seen again. The reality is that law enforcement agencies have many SARs to sort through and are going to focus on those cases which present significant risk to the financial industry, consumers, or national security. In this session we will discuss how to make your SAR stand out and be as useful as possible to law enforcement.
2:30 – 2:45 pm BREAK
2:45 – 4:00 pm Enhanced Due Diligence for Higher Risk Customers
One of the challenges a BSA Officer faces with higher-risk customers is how to put all the pieces of the puzzle together. Some customers have very specific documentation listed in the examination procedures, others do not. Ensuring that procedures are adequate to address all the various customer types, as well as use the information collected to support a documented conclusion is critical to demonstrating to our examiners that we understand customer activity.
Wednesday, March 27, 2024
9:00 – 9:45 am Suspicious Activity Reporting and Cyber Events
FinCEN has published advisories on cyber fraud, identity theft, ransomware, and a host of other cyber related crimes. It can be a challenge to know when a SAR is required, what dollar amount(s) to report, and how to identify this type of activity to protect our customers and our institutions. In this session we will explore the world of Cyber Crime as well as the types of crime highlighted on the SAR to help us navigate these ever-changing fraud patterns.
9:45 – 10:15 am Update on Digital Currencies
What’s the difference between game tokens, non-fungible tokens, and convertible virtual currency? Confused yet? Digital currency has been in the news recently, and for all the wrong reasons. However, that doesn’t mean that providing services to these customers is bad. It just means we have more risk to manage. In this session we will discuss the various types of digital currency, the risks that each can pose, and what due diligence measures we should take when we find one of our customers engaged in digital currency transactions.
10:15 – 10:30 am BREAK
10:30 – 11:15 am Update on the AML Act Implementation including the Corporate Transparency Act
FinCEN has completed two of its three rule makings to implement the Corporate Transparency Act. The Beneficial Ownership Secure System (BOSS) has received over 100,000 registrations from legal entities during the first couple of weeks of going live. But what does this mean for our financial institution? What happens? And what new regulations can we expect to see? In this session we will bring you up to date so you know what to share with your Board and Senior Management Teams as we prepare for what is to come.
11:15 am – 12:00 pm FinCEN’s AML/CFT Priorities and Red Flags for Identifying Suspicious Activity
FinCEN published eight AML/CFT priorities in June 2021, but we haven’t heard anything since. The notice stated there were no new rules or policy changes that were required of the industry, but that proposals would be forthcoming. 2 ½ years later and we haven’t heard anything further. In this session will bring these priorities back to the front burner and discuss what we should be considering in terms of higher risk businesses and patterns of activity that may require a second look to ensure we don’t have these types of suspicious activity occurring at our institutions.
12:00 – 1:00 pm LUNCH
1:00 – 1:30 pm SAR Decision Making
This session will be a prep session for the one that immediately follows it. We will review investigation methodologies, procedures for determining if a SAR should be filed, and documentation expectations for conclusions and supporting data. We will consider the use of SAR Committees in the decision-making process and steps for escalating alerts to cases, and meeting investigation timeframes to ensure timely SAR filing.
1:30 – 2:30 pm SAR Investigation Processes
This session is designed to be interactive, so be sure to bring your questions, procedural ideas, and investigation methods. The speaker will provide several scenarios where a reviewer receives limited transactional information from a system alert, spreadsheet, or staff referral. Participants are invited to ask questions or state what additional research they would conduct based on the limited information given. The facilitator will provide additional details about the case as the investigation “progresses” to simulate an actual investigation. At the end of each investigation, the participants can voice their opinions whether they believe a SAR should or should not be filed based on the information obtained during the discussion.
2:30 – 2:45 pm BREAK
2:45 – 4:00 pm The Future of AML/CFT Compliance: Artificial Intelligence
For AML/CFT Professionals that have spent many years in the industry, the prospect of changing how we identify, monitor, and report suspicious activity can be particularly intimidating. From manual reports, to rule-based systems, to machine learning in the span of a few decades shows that technology will continue to speed up before it slows down. In this session we will consider the potential risks and benefits that AI poses for our industry, and take a peek at what the future may hold.
*Note: Topics are subject to change based on new guidance or regulation that is published.
Class Materials
2024 BSA/AML 2-Day School - Day 1
2024 BSA/AML 2-Day School - Day 2
2024 BSA/AML Class Materials
The password to access the documents is BSA/AML2024
Credit Information
Day 1 up to 6.5 CPEs
Day 2 up to 6.5 CPEs
Attendees wishing to receive CPEs will be asked to sign in
and out of each day’s session. CPE certificates will be
emailed out within two weeks of the school.
Participant Roster
Check out who will be attending!
Instructor Information
Brian J. Crow
CAMS Managing Partner/Co-President, TCA
b_crow@tcaregs.com
Brian Crow is a nationally recognized Deposit Compliance and BSA/AML expert with a strong bank compliance management background and a welcome ability to provide focused educational support to TCA client banks. Mr. Crow most recently was BSA Administrator for a suburban Chicago bank, where his responsibilities included the bank’s annual assessment and audit documentation. Earlier, as Operations Officer at the same bank, Mr. Crow monitored AML activity and helped install automated AML software that allowed the bank to transition from paper to electronic CTRs. His activities were responsible for reducing debit card fraud by 95 percent at the bank.
Mr. Crow has been, and continues to be, an education consultant for the Glia Group BOL Learning Connect program, conducting webinars that have covered VISA/MasterCard chargebacks, debit card compliance and fraud prevention for hundreds of banks. It was in this role that Mr. Crow was recognized as a Bankers Online Guru in 2011. Like many of us, Mr. Crow began his banking career as a teller, working his way up to head teller and then branch management responsibilities. He earned a B.A. degree from Concordia University, River Forest, Illinois.