Includes Full Conference Schedule
|Pre-Conference Workshop |
BSA Immersion Workshop conducted by Ken Golliher
Monday, February 25th
Attend it as a stand alone seminar or
add it to the BSA Top Gun Conference
- Basic Training for the Generals: BSA/AML for Board Members
The Board of Directors is the expected audience for the bank's BSA/AML & OFAC risk assessments. They are the expected source for the bank's BSA/AML & OFAC policies. Thus, board members need a firm understanding of the bank's legal responsibilities in order to ensure that the bank's policies reflect the results of the risk assessment. This is a "how to" presentation on the development and implementation of a BSA /AML-related training program for board members. It shows attendees what points to emphasize, how to develop materials, and how to underscore training sessions with standard board reports.
- How BSA Required Reporting Is Used in Criminal Investigations
With legislation that would change the CTR filing threshold and a GAO study on the value of CTR filing pending, this session is a "must attend" for every BSA officer. An FBI representative explains how law enforcement agencies use the information from Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) to develop and pursue investigations into money laundering and terrorist financing. The presentation provides valuable insight into the cost justifications for the millions of CTR filings which take place every year.
- SAR or no SAR: You Decide
Interactive session with the audience serving as the SAR committee. When suspicious activity is reported to the committee the audience votes: SAR or no SAR. The exercise is based on real world scenarios. In some cases, the requirement to file a SAR will be clear. In others, the information will be parsed out to the audience in an incremental fashion to see at what point the scales tip in favor of filing. Panelists will discuss why filing is or is not necessary and cite available resources for guidance. Panelists will also discuss what a bank's explanation might be for not filing in some circumstances. (We cannot wait to see if our panelists always agree.)
- I thought I saw suspicious activity...or did I?
The FFIEC BSA/AML Examination Manual states that financial institutions are to perform tests to ensure the integrity and accuracy of management information systems. (MIS) used in the institutions BSA/AML compliance program. MIS includes reports used to identify large currency transactions, aggregate daily currency transactions, funds transfer transactions, monetary instrument sales transactions, analytical and trend reports and transaction monitoring programs. Yet what have been some common, and not so common, oversights in collecting these types of transactions to paint a true picture of your customers transaction activity? Was that CTR you filed accurate, or was it missing a few cash transactions? Was a system generated CTR prepared for a customer, yet the activity was actually the result of multiple checks written by non-customers? This session will discuss these and other miscues that are keeping examiners on their toes when conducting BSA/AML examinations.
- Risk Rating Business and Organizational Customers
The regulatory direction to identify "high risk" customers is clear. The simple method of "branding" customers with the "high risk" classification due to their lines of business has been debunked as inaccurate and a waste of valuable resources. This presentation assumes the bank has identified customers subject to expanded examination overview and is trying to differentiate between customers who deserve greater amounts of enhanced due diligence and those that do not. It gives attendees a method for using due diligence information to establish scores which can both add and remove customers from high risk classifications.
- Frequent BSA/AML Compliance Errors
No theory allowed in this presentation. Our panelists are all experienced in doing in-bank BSA-AML compliance audits. This session focuses on what they see as the most frequent compliance errors and regulatory criticisms. The panelists explain the types of violations, problems, and simple errors they see in their examinations of client institutions and how errors should be corrected to avoid repeat criticism in regulatory examinations. Panelists also address how compliance issues found in the independent examination should be reported to the board of directors, both initially and in follow up communications.
- I Know It When I See It: How to Train the Frontline
Contact personnel rarely join a bank's staff with a detailed understanding of what new account fraud or kiting looks like. Traditionally, too many banks rely on "on the job" training for those topics. While that approach is not wise on any topic, it simply will not work when employees are expected to recognize symptoms of money laundering or terrorist financing. They have to have well documented training that is directly connected to their specific responsibilities. In addition, high turnover on the teller line and the platform means decreased observation, discovery, and judgment of what should be reported as suspicious behavior. People involved in illegal activity frequently change their techniques and employee proficiency becomes a moving target. This session provides attendees with tips and ideas on how best to train frontline employees in order to make them the best watch dogs in your financial institution.
- Reviewing and Updating Your Bank's CIP: What Have You Learned?
The legal requirement for a formal Customer Identification Program (CIP) came from the USA PATRIOT Act. It required some simple tasks, obtaining four pieces of information and verifying enough of that information to form a reasonable belief of a customer's identity. Banks have had four years to live with their CIPs. This presentation focuses on whether or not it's time for a formal, critical analysis of that effort and how the effort should mesh with the bank's due diligence and enhanced due diligence efforts. In effect, the panelists walk attendees through the original construction of their CIPs and ask if they would make the same choices today given recent developments.
- Identifying High Risk Customers and Mitigating Their AML Vulnerabilities
For the past several years, numerous banks have been subject to civil and, in some cases, criminal enforcement actions for failing to adequately supervise and monitor activity occurring through accounts that pose a high risk of money laundering abuse, such as cash intensive businesses, money services businesses, private ATMs, and shell companies. This session will discuss successful measures that banks have taken to identify categories of such high risk accounts, how to identify these accounts from their customer base, and how to manage the risks posed by these accounts in a practical, cost-effective manner. This session will also discuss the pros and cons of retaining high risk customers that are the subject of repetitive suspicious activity reports. Materials will also be provided that discuss in more detail measures banks can take to effectively comply with Section 312 of the USA Patriot Act concerning private banking accounts, foreign correspondent accounts and senior foreign political officials and their family and business associates.
- FinCEN Update
The Financial Crimes Enforcement Network (FinCEN) is the financial intelligence unit for the United States and the administrator of the Bank Secrecy Act. Many, however, do not understand how FinCEN operates, what information they get, and how they work to help financial institutions stay in compliance. Tom Fleming, Assistant Director of FinCEN’s Office of Compliance, will discuss these issues, new initiatives at FinCEN, and explain how your efforts are helping in the domestic and global fight against money laundering and terrorist financing.
- Regulatory Enforcement Actions: What Should They Tell Us?
This institution got a $75 million civil money penalty based on BSA/AML violations. The other one only got a $25 million civil money penalty, but that amount, coupled with the extraordinary legal fees it incurred defending itself, effectively made it a candidate for acquisition and it ultimately ceased to exist. Those are some of the headline crucifixions, the ones that get all of the press. This session focuses on the enforcement actions that did not make the front page. Nevertheless these regulatory actions still reordered the near term and long term priorities of the institutions affected. This session analyzes the most recent actions as a source of guidance from the regulatory agencies as to what issues they believe to be critical and how they believe deficiencies should be remedied.
- BSA/AML in the Acquisition Process
Regulators are required to consider a bank's anti-money laundering record when reviewing bank mergers, acquisitions and other applications for business combinations. In addition, an acquisition can have an “overnight” effect on a bank's BSA/AML risk assessment. This session features a case study involving two real banks, one the acquirer and the other the acquired. The panelists address the issues involved and discuss how a bank's BSA/AML compliance effort makes it more or less attractive to an acquiring institution as well as how a poor AML effort can impair the value of the institution being acquired. The presentation also addresses the practical elements of integrating varying procedures and philosophies that any two banks are bound to have.
- Risk Based Analysis
Okay, you are tired of being told that every BSA/AML compliance decision you make is risk based. Who isn’t? You just want some so-called expert to simply tell you what to do so you will get a passing grade in your next on site examination. In this session some of those BSA experts address the concept of risk based analysis and provide some parameters for how to apply it in the day to day construction and design of your compliance efforts. The session is based on practical, real world examples focused on the idea that the concept of a “risk based” program is a positive concept, one that provides banks with the flexibility to develop a program they can both rely on and cost justify. The concept is applied to individual and aggregated decisions as a form of illustration.
- Training for CTR Completion: The Unanswered Questions
Sole proprietorships, TINs for government entities, proper addresses for local businesses with more than one location, aggregation for commonly owned entities – there are still legitimate questions on the proper completion of a form, even one whose current version was published more than 10 years ago. Even when there is no official answer, in-house training must provide employees with consistent answers on how a form should be completed in specific fact situations. In this session panelists illustrate those common problems and give suggestions on how to train when there are no firm answers from FinCEN.
- New Payment Products and Their AML Implications
Clearly, there is no place where laws and regulations struggle more in their efforts to match the pace of technology than in the design of bank products. The development of new payment products and new payment portals is virtually continuous. The law, on the other hand, is relatively static. Bank products that offer convenience and anonymity to people involved in money laundering and terrorist financing pose a special concern. This presentation focuses on a discussion of emerging products and how banks should evaluate the AML risks inherent in some of their new services ranging from their internal controls and audit coverage, and to their employee training.
- BSA/AML Related Internet Resources (Including BOL)
What are your best resources when you have a BSA compliance question? What if you need a little bit more information on an out of state corporation that wants to open an account? What specific types of information can you obtain from the BankersOnline web site? How do you make certain that notices of all BSA/AML related developments cross your computer screen every day? Conducted by Internet Gurus, this session is a must attend.
- Kathleen Blanchard
Kathleen Blanchard is a principal with Key Compliance Services, a consulting firm specializing in bank compliance, CRA and fair lending analysis. She has over 22 years of banking experience at banks ranging in size from $2 billion to some of the world's largest banks.
Kathleen has held banking positions ranging from Credit Analyst to Commercial Lender, Credit Review Officer, Credit Support (workout) Officer, VP/Credit Officer, VP/Credit Policy and Procedures Manager, VP/Senior Compliance and Control Manager, SVP/Compliance Manager and FSVP/Risk Manager.
Her extensive experience with commercial and consumer lending, regulations, policies and procedures and bank wide controls allows her to help banks to develop workable processes to meet regulatory requirements. She has established compliance and CRA functions from the ground up and has extensive policy and procedure and credit risk management experience.
She holds CRCM and CRP certifications and is a graduate of the ABA National Compliance School. Kathleen has extensive experience conducting training on many topics and has presented at conferences on banking topics and Sarbanes Oxley as it relates to banks. She has written white papers on banking issues and been published in the ABA Banking Journal and Compliance Week.
- John S. Burnett
John Burnett is a 1979 alumnus of the ABA National Compliance School, and served on its faculty for several years. He graduated with honors with the Class of 1990 from ABA's Stonier Graduate School of Banking. He is also a graduate of the BAI's and the Massachusetts Banker Association's Schools of Banking.
He joined Cape Cod Bank and Trust Company in 1971 and assumed his role as Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, as well as Clerk of the bank's holding company. John joined Glia Group, Inc., and became a part of the BOL Team in June, 2004.
Mr. Burnett is a former member chair of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He served on ABA's Truth in Savings Task Force, and has served on several ABA and Massachusetts Bankers seminar panels.
- Brenda Canterbury
Brenda is Senior Vice President and Corporate Compliance Specialist of Alabama National BanCorporation headquartered in Birmingham, Alabama. She is responsible for Bank Secrecy Act and anti-money laundering internal audits for ANB affiliate banks in Alabama, Georgia and Florida; as well as oversight of deposit compliance, privacy and information security programs.
She began her banking career in 1978 and has extensive experience in developing and managing BSA, deposit, branch audit and information security programs; conducting enterprise-wide risk assessments; and developing effective operational and compliance manuals in community bank environments. In addition, she has served as an active member of the company's merger/acquisition team for over twenty years, assisting in over 25 bank mergers and acquisitions.
She holds the designation of Certified Anti-Money Laundering Specialist and has been a speaker/trainer for civic organizations, Community Bankers Association of Alabama and the Center for Financial Training (formerly known as American Institute of Bankers).
- Randy Carey
Randy Carey is an independent regulatory compliance and bank management consultant. He has nearly 30 years of banking experience which included positions ranging from Check Sorter Operator, Proof Supervisor, Senior Training Officer, Staffing Analysis Officer, VP and Project Manager, National Retail Loan Payment Processing Manager, VP - Compliance and Community Reinvestment Act Activities, and VP and Director of Internal Audit. Randy utilizes his broad base of banking operations knowledge to help banks meet the challenges of regulatory compliance by suggesting practical solutions that are both effective and efficient. He is a graduate of the ABA National Compliance School, the ABA National Graduate Compliance School, and the ABA National Truth-in-Lending School. He has served as an instructor for both the American Institute of Banking and the Oregon Bankers Compliance Schools and passed the Certified Bank Compliance Officer examination. He is also a former member of the Community Reinvestment Leadership Council of the Federal Reserve Bank of San Francisco.
- David Dickinson
David is a highly trained expert in compliance regulations. He is also a motivational speaker and innovative educator. As a qualified speaker on compliance issues, David speaks for the American Bankers Association's National Compliance School, as well as several State Banking Associations. He conducts various seminars throughout the year, has developed numerous compliance manuals and has written articles for prestigious banking publications. In 1993, he established the firm of Banker's Compliance Consulting.
- Peter Djinis
Peter Djinis is the founder of the Law Offices of Peter Djinis, specializing in civil and regulatory matters involving federal anti-money laundering and Bank Secrecy Act laws. Before establishing his own law offices, he served as Executive Assistant Director for Regulatory Policy for the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN), where he was responsible for establishing regulatory policy and overseeing all aspects of Bank Secrecy Act (BSA) compliance by US bank and non-bank financial institutions. Peter is the author of The ABC's of the BSA, a reference book on BSA regulatory requirements. He often speaks on money laundering and Bank Secrecy Act compliance matters and has frequently appeared in the national media and testified before Congress.
- Thomas Fleming
Mr. Fleming is the Assistant Director for the Office of Compliance at the Financial Crimes Enforcement Network (FinCEN). The Office works to better ensure industry compliance with the Bank Secrecy Act through supporting, overseeing, and working in partnership with the agencies and organizations that examine for Bank Secrecy Act compliance. The Office also tracks the performance of financial institutions experiencing significant Bank Secrecy Act compliance deficiencies. As Assistant Director, Mr. Fleming has overall responsibility for managing these efforts and outreach initiatives to educate financial institution, regulatory, and law enforcement partners on these matters. Previously, Mr. Fleming served as the Assistant Director for the Office of Regulatory Policy at FinCEN. In that Office he oversaw the issuing of Bank Secrecy Act (BSA) regulations and guidance to interpret and clarify BSA regulations and policies.
- Ken Golliher
Ken Golliher is a principal with Pegasus Educational Services, LLC, a training firm headquartered in Louisville, Kentucky. He is an experienced banker with a unique ability to reduce complex legal concepts to plain English. He has explained the "why" and "how" of regulations to thousands of financial institution personnel and examiners. Ken's banking career began in 1972 and includes serving as a teller, commercial operations manager and as trust department legal counsel in a state and a national bank. For ten years he headed the education division of a regional consulting firm for financial institutions. He has served on the faculty of the LSU Graduate School of Banking, the OTS' Level I Compliance School and the FDIC's Advanced Consumer Protection School for examiners. He has presented seminars in more than 25 states and has served as an instructor at compliance schools sponsored by the Illinois, Indiana, Iowa, Georgia, Kansas, Kentucky, Nebraska, Oklahoma, Pennsylvania and Texas bankers associations. He is a member of the Society for Applied Learning Technology. He is also a moderator of the General, BSA, and Operations forums at BankersOnline.
- Mary Beth Guard
Mary Beth Guard currently serves as Executive Editor of BankersOnline.com and CEO of Glia Group, Inc., Mary Beth has had a long and distinguished career, graduating from law school in 1980, then going on to serve as general counsel for the Oklahoma State Banking Department, general counsel for the Oklahoma Bankers Association, and EVP of Specialized services for Thomson Financial Publishing prior to co-founding Glia Group, Inc. and BankersOnline.com. Mary Beth also serves as Executive Editor for BankingQuestions.com and as a partner in BankGuard Resources.
Mary Beth is on the advisory board for BANKERS'Hotline. She has presented training programs for virtually every major national financial industry association, as well as more than a dozen state bankers associations and a host of other organizations. In addition, Mary Beth has written more than a thousand banking-related articles and is a BOL Guru.
- Michelle Hassen
Michelle has been in the banking industry for the past 19 years with her career beginning as an Examiner for the Federal Reserve Bank of Kansas City, Denver Branch. She was initially a Safety and Soundness Examiner and then transitioned to Compliance Examiner. She then crossed over to the bank side and became a Compliance Officer for one of the larger banks in the country responsible for compliance of two states and over 45 branches. Michelle then moved to become a Compliance Consultant for a large accounting firm in the Chicago area. There, she assisted in writing several compliance manuals and created various compliance tools for the industry.
For the past ten years, Michelle has been responsible for the Compliance/Bank Secrecy Act/Anti-Money Laundering Program at Corus Bank, a $10 billion organization based in Chicago, IL. While the bank's primary focus is on Commercial Lending across the United States, the bank is a large provider of banking services to the currency exchange/check cashing industry in the Chicago metropolitan area. Michelle graduated from the University of Denver with a Finance and Marketing degree.
- Barbara Hurst
With a background in public relations, followed by 15 years in the banking industry as head of a department in charge of claims, security training, and Bank Secrecy Act compliance, Barbara has been teaching these subjects and others for the past 18 years. In her position as editor of BANKERS'Hotline, she works at staying on top of what is happening in the banking industry and how it affects the security function. Her presentations combine information with humor, and she tends to attract speakers of similar talents to her workshops. Barbara has taken security and compliance programs and presentations to 44 states and internationally, for bankers, governments, and law enforcement.
- Betsy Maesen
Betsy B. Maesen currently serves as Program Coordinator within the Office of Outreach Resources at the Financial Crimes Enforcement Network (FinCEN). The activities of the Office of Outreach Resources include participation in, oversight of or support for interagency and international working groups, the Bank Secrecy Act Advisory Group (BSAAG), the Bank Secrecy Act Resource Center, the Financial Action Task Force (FATF), and networking with officials of federal, state and local law enforcement and regulatory agencies. Daily, Betsy provides guidance and other assistance to financial institutions that are trying to comply with anti-money laundering program requirements, customer identification program requirements, and currency transaction and suspicious activity reporting. Betsy has participated in the Federal Financial Institutions Examination Council's (FFIEC) Advanced BSA/AML Specialists Conference and has participated in the Cyberfraud Working Group. Betsy also mentors and provides training to FinCEN staff members.
Prior to joining FinCEN, Betsy worked within the government relations field. Betsy specialized in Social Security and government employee issues and she routinely communicated with members of Congress and their staffers. Betsy obtained a Master of Arts in Congressional Studies from the Catholic University of America in Washington, D.C. and she obtained her Bachelor of Arts in Community Leadership from Aquinas College in Grand Rapids, Michigan.
- Paul Osborne
Paul is the national executive responsible for directing the development and support of regulatory advisory services, focusing on consumer compliance, BSA/AML and terrorist financing risk assessments, BSA/AML independent audits, trust department operational and administrative reviews, BSA/AML and trust training, assisting clients with developing functional and effective BSA compliance management programs, consulting with clients and prospects on the feasibility of establishing fiduciary services, and responding to client inquiries with respect to particular regulations or their application. Crowe currently provides compliance and trust consulting services to over 400 financial institution clients nationwide.
Paul has over twenty-five years of experience in the banking industry, mostly with a large multi-state bank holding company. While with the banking holding company, his responsibilities included the management of compliance, community reinvestment, real estate appraisal, and environmental liability for the holding company's affiliates in Illinois and Indiana, with the affiliate in Indiana being the largest FDIC chartered bank in the state.
He manages BSA/AML risk assessment projects, transaction look-back investigations and BSA audits for three of the nation's largest financial institutions and the world's third largest money service business. Paul was also a member of the Crowe team assisting Riggs Bank with addressing Department of Justice enforcement initiatives. Some of Paul's former and current clients include: Key Bank, BB&T, Comerica, BankAtlantic, First National of Nebraska, Inc., and Colonial Bancgroup.
Paul and certain professionals of his team were also involved in the early stages of CRA Wiz development, assisting various banking organizations with utilizing the software's functionalities in analyzing CRA performance criteria.
- Laura Williams
Supervisory Special Agent Laura Williams, a Certified Public Accountant, received her Bachelor of Science degree in accounting from the University of Delaware. Following graduation she became an accountant for the U.S. General Accounting Office where she conducted program reviews and financial audits of government corporations. In 1986, SSA Williams entered on duty as a special Agent with the Federal Bureau of Investigation. She has had investigative assignments in the Phoenix, Baltimore and Washington DC field offices, focusing mostly on white-collar crime investigations. In 2003, SSA Williams was promoted to her current position as the FBI's Liaison to Treasury's Financial Crimes Enforcement Network. In this capacity, SSA Williams, whose office is located at FinCEN's headquarters in Vienna, VA, coordinates a wide variety of investigative, program and policy matters between FinCEN and the FBI.
- Andy Zavoina
Andy has been in finance and banking for 22 years. Over 20 years were with a holding company with two Central Texas community banks that had $534 million in assets, 89 branches spanning Texas and nearly 500 ATMs. After starting in loan workouts, Mr. Zavoina has been a consumer, commercial and real estate lender and managed those departments as well as being the banks first Webmaster. He was responsible for compliance- management, -auditing, and -training for both banks.
Andy is a past Chairman of the American Bankers Association's Compliance Executive Committee. He was the 2003 recipient of the American Bankers Association's Distinguished Service Award for his involvement and accomplishments in the field of regulatory compliance management. He currently serves on the Editorial Advisory Board for the ABA's Compliance Magazine, Compliance Action magazine, is a member of the ABA's Compliance School Board and is a BankersOnline Guru. He also served on the Texas Bankers Association's Compliance Committee.
He is a graduate of the ABA National Commercial Lending School, National Compliance and National Graduate Compliance School and is a Certified Regulatory Compliance Manager with the Institute of Certified Bankers. He has written numerous articles and lectured on compliance, the use of the Internet and technology as a tool, as well as compliance in cyberspace to local, state and national associations. Internet policies and other compliance related programs are made available on his personal Web site.