Money laundering continues to be a national concern. High levels of drug-related activity and violence have drawn additional attention. Terrorist activities need to be considered as well. Perpetrators have adapted to banks’ efforts so banks cannot combat money laundering with yesterday’s methods. Software is widely installed to identify specific patterns and “unusual” transactions. But the launderers know this and are constantly striving to create new patterns where their transactions are designed not to be flagged. Like in a game of chess, the advantage goes to the side that thinks the most moves ahead.
This webinar will provide valuable assistance to all personnel with AML responsibilities in banks or other financial institutions:
We will also cover the new CDD requirements, which are formidable. They will impact commercial, small business, private, and international banking areas of the Banks as well as compliance officers and areas currently performing KYC tasks. New research will be required on new entities never addressed before in customer acceptance. Follow-up will require new updating requirements and a strong linkage of monitored transactions versus baseline.
o Know Your Customer (KYC)
o Currency Transaction Reports (CTRs)
o Suspicious Activity Reports (SARs)
o Customer Due Diligence
o Three covered entity types
o Customer legal entity
o Beneficial owners
o Controlling persons
o Exclusions
o New Requirements
o Risk profiles
o Updating
o Baseline/normal transactions
o Transaction monitoring
FinCEN has issued substantial new AML requirements focused on a major expansion of Know Your Customer into what is now Customer Due Diligence, CDD. It goes far beyond knowledge of the Customer's Legal Entity to the Beneficial Owner of that entity and its Controlling Persons. It is focused beyond the initial customer acceptance step, requiring updating and ongoing monitoring against baseline “normal” activity for the customer type. It is very unlikely that many banks already comply with these requirements. Compliance implementation is required by May 11, 2018.
Jim George is an independent consultant to banks focusing on issues of fraud. He brings over 25 years as a consultant to major banks in Associate Partner and Principal roles at PriceWaterhouse-Coopers Consulting, IBM Consulting in Bank Risk and Compliance and Andersen Consulting (now Accenture). He has also been SVP Operations for a Fortis-US division providing outsourcing services to the banking industry.
Jim's work has included projects in fraud investigation, fraud prevention, identity issues, compliance and AML (anti-money laundering). His background includes work in bank operations and payments strategy, reengineering, systems and quality improvement.