FinCEN and the banking regulators have recently proposed a major re-write of the AML/CFT program requirements. This proposal, which has a very high likelihood of being finalized much as proposed, will cause every regulated financial institution to take a fresh look at their program, how they do things, and refocus on how their BSA/AML tasks are performed. We’ll delve deeply into the proposal and discuss what it means, and what to do to prepare for the changes.
This proposal is part of the AML Act, so we’ve known its coming for some time. But it memorializes the requirement to perform a risk assessment, refocuses compliance efforts on high-risk areas, and involves FinCEN much more into the regulatory process, among other changes. We’ll make sure you have the information you need to meet expectations and plan for the changes in your program.
What You’ll Learn
- Consolidation of the rules into a single standard applicable to all institutions
- Providing for “greater flexibility” and focus on high-risk areas
- Inclusion of federal AML/CFT priorities
- FinCEN’s role in the supervisory process
- Assuring the “effectiveness” of your AML/CFT program – this is primary!
- Establishment” and “maintenance” of your program – what does this mean?
- Changes to the 4 pillars of BSA/AML compliance
Who Should Attend
Anyone involved in financial crimes compliance.