 Tuesday, February 24, 2009 ( 7:33 PM ) John Burnett BOL Conferences 3rd Annual BSA/AML Top Gun Conference Bally's, Las Vegas Day 1 -- Tuesday, February 24 I'm in Las Vegas for much of this week, participating in BOL Conferences' BSA/AML Top Gun conference. This is the third annual event, and it shows early signs of being the best of the series. Mary Beth Guard and Ken Golliher welcomed to the conference over 150 attendees from all over the country (and two from outside the US).  FinCEN Update FinCEN's Thomas Fleming started his presentation by suggesting that there needs to be a balance between reactions to the current economic crisis and BSA/AML compliance. With limited -- often shrinking -- resources, bankers have to decide where they must focus, and what they can let go. From the government's perspective, BSA/AML/OFAC compliance continues to be a national security concern. That suggests, he said, that bankers should fine-tune their approach to compliance by focusing on higher risk activities, customers and products, remembering that customer behavior will change in troubled economic times, particularly with regard to the safety of their dwindling funds. Tom next recapped the events leading up to the recent revision to the CTR exemption process, and followed with a list of current and pending FinCEN initiatives affecting the industry. The first of those was today's FinCEN release of a new customer education brochure regarding CTR filings and structuring (the agency's email alert of the release hit my BlackBerry at 7:56 a.m. PST). Other releases on the horizon include --
OFAC Technology was stretched a bit as Mary Beth and her iPhone became the go-betweens for OFAC's Jerry LiVigni, who had to "call in" his presentation from his office. Jerry's message advocated a reasonable approach to OFAC compliance, based on a bank's risk analysis. ID Theft and CIP Implications Pat Cashman, Ken Golliher and I compressed our impressions on this topic into a 30-minute slot just before lunch. We illustrated the connections between compliance with ID theft "Red Flags" regulations and CIP rules, and then listed some of the pros and cons of merging Red Flags and CIP policies and procedures.  CSI -- Common Slip-up Investigations The presentation slot right after lunch is always a challenge. Pat Cashman and Dave Dickinson were up to the task, though, with their entertaining look at common screw-ups (if it's good enough for the president, it's good enough for me) that can get banks into trouble at audit or exam time. Mortgage Loan Fraud Mary Beth gave us all a quick overview of the huge problem of mortgage loan fraud that has been a major contributor to the global economic recession and continues to threaten banks and other mortgage investors. She punctuated her remarks with examples of the many varieties of mortgage fraud that have been involved, and encouraged bankers to develop methods and procedures designed to identify and prevent fraud in the loan application process.  Exam Prep David and Ken teamed up to discuss tips for preparing for regulatory exams. Strategies and tactics to make the exam process smoother and more efficient were high on their list. They ran from making sure that issues identified in prior exams and audits are addressed, to ensuring that staff members are prepared for the exam, to preparing and delivering pre-exam information, to a follow-up "party" to thank staff members for exam successes. The day wrapped up with a Q&A session and reception. I'll be back with an update covering Day 2 of the 2009 Top Gun Conference.  --JB Labels: BOL Conferences, BSA/AML, conference # |
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