BSA/AML Contextual Awareness of High Risk Customers

Duration: 60 Minutes
This presentation will provide the practical steps to enable your institution to meet both the letter and spirit of the law and regulation. Learning from real-world audit issues, the presentation will cover what many banks are doing incorrectly and what they should be doing instead.
High Risk Customer Reviews
Instructor: Thomas Nollner
Product ID: 505365
Objectives of the Presentation
  • An overview of FinCEN and FATF requirements
  • Defining and clarifying the written requirements with the spirit of the law
  • Three common mistakes institutions make when identifying high risk customers
  • How to ensure existing and new high risk customers are identified properly
  • How to perform high risk customer reviews that have tangible benefits for the BSA Program
  • How to efficiently and accurately leverage internal resources and knowledge for the benefit of the high risk customer program
  • Real-life examples of high risk customer reviews with tips on how to use these in your operational environment
  • How to avoid examiner and regulator criticism regarding high risk customer reviews
  • Understand the tangible benefits and net effect of your institution’s efforts
Why should you Attend
Ongoing high risk customer reviews has been a requirement since the first FinCEN Exam Manual was published in 2005. The recent guidance for Customer Due Diligence/Enhanced Due Diligence (CDD/EDD) further defines the expected approach for institutions to properly identify and evaluate high risk customers. The regulators have not, however, detailed the day-to-day approach required to meet this required customer monitoring.

Areas Covered
  • Background related to the need for information about high risk customers
  • FFIEC guidelines for determining high risk customers
  • FinCEN expectations for a good high risk customer program
  • Items to include in your high risk program
  • Current issues related to the high risk process
  • Recent enforcement actions addressing weak high risk programs
Who will Benefit
  • Front line BSA/AML Staff
  • Account Opening Staff
  • Risk Managers
  • BSA/AML Officers
  • Compliance Officers
  • BSA/AML Audit Staff
  • Auditors
  • BSA/AML Consultants
Topic Background
A basic component of a good Know-Your-Customer Program is identifying and monitoring high-risk customers. In order for a financial institution to properly conduct customer account review and monitoring, the institution must risk rate its customers and determine those that are higher risk and -risk so these accounts can be monitored more closely.
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  • Upon purchase of the recorded session a link will be updated on your OCP Account within 24 hours
  • Please click on the link to access the Recorded Session
  • Presentation handouts in downloadable PDF format will be updated on your OCP Account within 24 hours of the purchase of the product
  • Download the Certificate of Attendance and Purchase Invoice from your OCP Account after 48 hours of the product Purchase
  • Please share your valuable Feedback at the end of the session
Instructor Profile:
Tom Nollner has over 35 years of experience in the banking regulatory field. His experience includes 30 years as a National Bank Examiner for the Office of the Comptroller of the Currency, United States Treasury and 5 years as an international banking consultant. He has a proven track record in assisting financial institutions regarding capital adequacy, asset quality, management issues, earnings concerns, and liquidity. In addition, Tom is a consumer specialist focusing on developing and instituting risk management processes, and in implementing anti-money laundering related programs and policies.

Tom has developed and presented numerous training programs focusing on banking issues, to regulatory authorities, government bodies, and the staff of financial institutions in countries in North America, Asia, the Middle East, the Caribbean, and South America. In addition, he has developed banking policies and examination procedures for regulatory authorities, and assisted Financial Intelligence Units and Central Banks with improving existing banking laws and regulations.
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