Top Gun - Day 2

FinCEN Assistant Director for the Office of Compliance Tom Fleming provided us all an update on what's going on at FinCEN, a bit of the office's history, and a lot of background on FinCEN's several missions. We were all delighted to hear Tom say that FinCEN keeps an eye on BOL's Bankers' Threads as a barometer of industry BSA/AML concerns, and particularly pleased when Tom acknowledged the key role that bankers play in providing information for FinCEN to act upon, and extended FinCEN's thanks for our collective efforts. Several bankers commented that it was the first time they could recall being thanked for the industry's BSA/AML work. We think Tom was a "hit" with many of the bankers at the conference.

Tom also pointed out that while BSA was once a regulation of "i" dotting and "t" crossing, it is now a regulation of national security.


John Burnett

They've "been there, done that, and got the T-shirt." Brenda Canterbury was with the acquired bank. As of now, she's joined Megan Hodge of RBC Centura Bank, which completed its acquisition of Alabama National BanCorporation three days before this year's Top Gun BSA Conference began. They were the perfect duo to present our breakout session on "BSA/AML in the Acquisition Process." Together, Brenda and Megan offered valuable advice on managing the process to maintain the credibility of the combined BSA/AML compliance program. Much of that advice would apply to any operational unit during a bank acquisition, but as Brenda and Megan noted, it's extremely critical in the BSA/AML arena.



Ken Golliher and Brenda Canterbury

Our panel of Tom Fleming, Brenda Canterbury and John Burnett went through a long list of CTR preparation questions in their "Training for CTR Preparation: The Unanswered Questions" breakout session. Yet there were still more questions, as participants came prepared with scenarios of their own. John carefully analyzed FinCEN's latest ruling on CTR completion for DBAs - sole proprietors and entities - and noted the flexibility that FinCEN built into their answer to the DBA quandary. Tom also noted that FinCEN is working on updating old advisories and rulings to better reflect current practice.