BSA/AML & OFAC Compliance - Part II

Some people might think that regulatory attention to the BSA has let up over the past couple of years, given other difficulties and areas of concern, such as fair lending, TRID, HMDA, and UDAP. Think again. With the safety and soundness of the entire industry the focus of news stories every day and many well-publicized enforcement actions, the regulators obviously haven't eased up. These rules are still very close to being the #1 issue facing compliance officers.

In Part 2, we’ll discuss the Customer Identification Program (CIP) rules, other BSA reporting, including funds transfer recordkeeping, PEPs, pouch rules, and the Office of Foreign Asset Control (OFAC) regulations.

We'll also talk about where the risk areas are and where examiners are criticizing institutions. Your comprehensive program must be continually updated, and we'll make sure you have the information you need to meet expectations.

Covered Topics Include:

  • BSA program requirements, including the 4 (5?) pillars
  • Updating your risk profiles, including due diligence responsibilities
  • Currency Transaction Reporting hotspots, including exemptions
  • Suspicious Activity Reporting - the backbone of an effective BSA program
  • Due diligence responsibilities, including Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk customers
  • Selling monetary instruments for cash - collecting and retaining information
  • Money Services Businesses (MSBs) – a special type of customer
  • Funds transfer recordkeeping - more information collection
  • OFAC rules – who and what to screen?
  • Blocked & rejected transactions - what's the difference and how do I know which to do?
  • Additional USA Patriot Act requirements, such as 314(a), PEPs, and Pouch activities
  • Identifying customers and maintaining proper evidence under CIP rules
  • Regulatory reorganization of BSA rules
  • FinCEN hotspots and areas for review
  • And more