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#1865755 - 10/28/13 08:27 PM Poll Question - What is your opinion?
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
Question for my fellow BSA/AML professionals:

What do you think will be the top two BSA issues / hot topics for 2014 ?

Thanks!
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#1865771 - 10/28/13 08:52 PM Re: Poll Question - What is your opinion? CantBeShocked
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
If FinCEN ever rolls it out, beneficial ownership info requirements.
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#1865772 - 10/28/13 08:54 PM Re: Poll Question - What is your opinion? CantBeShocked
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
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I continue to hear about automated BSA/AML systems not being validated adequately.
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#1865777 - 10/28/13 09:07 PM Re: Poll Question - What is your opinion? CantBeShocked
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
Agree with manimal.

Also, periodic verification that if you are using an automated OFAC check, that you've got the current SDN. Once our core processor tells us that they've updated the system for an SDN change, we periodically take a name or two that has been added to the SDN and check that our automated system can find it.
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#1866389 - 10/30/13 01:41 PM Re: Poll Question - What is your opinion? Doug Hendrickson
Cape Codder Offline
Gold Star
Joined: Jul 2011
Posts: 413
Although it may not reach the Top Two BSA Issues, I'd be surprised if we don't hear a lot more about virtual currencies (of course, we first have to figure out how to identify the activity).
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#1866792 - 10/30/13 08:27 PM Re: Poll Question - What is your opinion? CantBeShocked
Dr.Ozya Offline
Member
Joined: Mar 2013
Posts: 87
Phila
#1 of the two - I hope, we all will be busy with implementing clear, wise and logical directions of 2013 BSA/AML FFIEC Manual. Another is standardization of BSA risk assessment format that will also be directed by the new Manual.

Everyone is allowed to dream, right?
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#1867246 - 10/31/13 06:57 PM Re: Poll Question - What is your opinion? CantBeShocked
Havanacat19 Offline
New Poster
Joined: Oct 2013
Posts: 2
I would like to see expansion of required data for EFT esp. ACH, and standard minimums for state beneficial ownership transparency.

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#1867296 - 10/31/13 07:59 PM Re: Poll Question - What is your opinion? CantBeShocked
Compliance Nut Offline
Member
Joined: Mar 2007
Posts: 88
How about FATCA? We are not a foreign bank, but do have foreign domicle customers. I think the push to find customers who are hiding income, using Tax Havens, etc. is coming to the forefront.

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#1867299 - 10/31/13 08:03 PM Re: Poll Question - What is your opinion? CantBeShocked
Beachbum, CRCM Offline
Gold Star
Joined: Dec 2006
Posts: 499
Knee Deep in Regs
I agree with Dr Ozya. Although they found no issues, the examiners spent alot of time reveiwing our BSA risk assessment.
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#1867344 - 10/31/13 08:38 PM Re: Poll Question - What is your opinion? CantBeShocked
happyauditor Offline
Platinum Poster
happyauditor
Joined: Nov 2004
Posts: 812
NY
AML model validation - that was the hot topic at the OCC Mid-size Bank BSA Roundtable this year.
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#1867714 - 11/01/13 06:53 PM Re: Poll Question - What is your opinion? CantBeShocked
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
FinCEN's evolution. At one time, there were more than twice as many people in the "compliance" area as in the "enforcement" area. Since the reorganization, that relationship has turned upside down.

It was the enforcement, not the compliance, personnel who were labeled as "essential" during the government shutdown...
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#1867793 - 11/01/13 08:40 PM Re: Poll Question - What is your opinion? CantBeShocked
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
Based on what I've seen and been hearing,vit's model validation for AML software and risk assessments. My clients are getting crushed in these two areas.

If the ANPRM for BO actually goes through, that will will be number 3.
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