I attended Ken Golliher's seminar yesterday in Tulsa, it was very informative. I understood him to say that even if we don't do international transactions at this time, that he would still advise us to address Section 311 (Special Measures) of the USA PATRIOT Act in our policy/procedures. I was hoping someone
could weigh in on this for me.
Among credit risk, market risk and operational risk, developing a good operational risk management program seems to be the most challenging. Can't our existing compliance processes (e.g., AML, Red Flags, GLBA, etc.) contribute to operational risk management?
Where can I find the verbiage for the CIP notice?
Is there any published reading on banking foreign corporations and how to become familiar with ones such as Mexican, Venezuelan, Bahamian, etc? We want to continue to bank foreign corporations, but want to ensure we are doing what's required by OFAC and Fincen.
An analysis of CTRs tied to terrorism raises some interesting facts which should be useful in your BSA program.
FinCEN has published the latest status of actions using Section 314(a). Requests to financial institutions have resulted in 77 arrests, 72 indictments and the location of $14,405,053.64.
FinCEN's 8th SAR Activity Review studied 2,175 SARs reported during that period.
In the world of compliance, we sometimes face requirements that appear contradictory, what we like to call dueling regulations.
It may seem like a heavy compliance load to you, but Section 314(a) provides valuable data for law enforcement types. And the information does not sit unused in some warehouse.
by David P. McGuinn, President, Safe Deposit Specialists