Some people might think that regulatory attention to the BSA had decreased 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. This is a timely topic, as provisions of the National Defense Authorization Act (NDAA) will transform several aspects of the BSA over the coming months and years, including the Beneficial Owner rules as well as incorporating AML/CFT priorities into institutions’ BSA policies. The rulemaking processes for these changes is already underway in 2022.
The Beneficial Owner rules that became effective a few years ago will be changed in the near future, although to what extent we don’t yet know. In fact, we can’t cover all the intricacies and details of both BSA/AML and OFAC in just one webinar. This is therefore a 2-part series, where we’ll discuss in Part 1 the Bank Secrecy Act provisions in general, including program requirements, risk assessments, CTRs, SARs, and the Beneficial Owner provisions, among other things.
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.
In both sessions, we’ll 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.
BSA/AML & OFAC Compliance – Part I
April 20, 2022, 10:00 am CDT
- Latest legislative and regulatory developments
- Purpose of the Bank Secrecy Act
- BSA program requirements, including the 4 (5?) pillars
- The BSA risk assessment process – factors and ratings
- Currency Transaction Reporting hotspots, including exemptions and possible changes
- Suspicious Activity Reporting – the backbone of an effective BSA program
- Due diligence responsibilities, including Customer Due Diligence (CDD)
BSA/AML & OFAC Compliance – Part II
April 21, 2022, 10:00 am CDT
- Beneficial Ownership rules – where we stand now and what will be changing
- Enhanced Due Diligence (EDD) for high-risk customers
- Money Services Businesses (MSBs) – a special type of customer
- Selling monetary instruments for cash – collecting and retaining information
- Funds transfer recordkeeping – more information collection
- Information sharing provisions under the USAPA
- Marijuana and hemp banking
- Elder abuse
- Human trafficking
- Digital currencies and related issues
- Identifying customers and maintaining proper evidence under CIP rules
- BSA enforcement and penalties
- OFAC rules – who and what to screen?
- Blocked & rejected transactions – what’s the difference and how do I know which to do?
- And more
Who Should Attend
These rules impact most anyone in your institution who has direct dealings with customers, such as Customer Service Representatives and tellers. But others are impacted as well, like loan officers and others who make important customer-related decisions. Compliance officers, auditors, attorneys, and management too will benefit from this information, as well, as they often are the ones who must draft these complex programs, administer them, and audit them.