* Saturday's events will be held at the Crowne Plaza located across from the Westin Diplomat (4000 South Ocean Drive, Hollywood, Florida; 954-454-4334).
Workshop A: Dissecting the Recent Major U.S. Justice Department ‘Deferred Prosecution Agreement’ and ‘Civil Money Laundering’ Cases for Their Vital Lessons in Good Compliance
Many of the recent serious actions against banks have been filed not by the regulatory agencies but by the U.S. Department of Justice from Washington or from various U.S. Attorneys’ offices around the nation. American Express Bank International, BankAtlantic in Florida, Union Bank of California, Lloyds TSB Bank, and Bank of Cyprus have suffered forfeitures or face serious lawsuits in which the consequences can be severe. Some of these legal actions have been filed on novel grounds that have few precedents. In some cases the amounts the Justice Department seeks are astronomical and run into nine figures.
In cases filed in New York City by the U.S. Attorney’s Office against the Bank of Cyprus, the government is seeking a judgment against the bank for $162,000,000. In the case filed against Lloyds TSB Bank, the U.S. Attorney’s office is seeking $130,000,000.
In three “Deferred Prosecution Agreements” filed by the Justice Department, American Express Bank International, in Miami, paid $65,000,000, Union Bank of California paid $32,000,000 and BankAtlantic, in Florida, paid $10,000,000.
How do these actions commence? How should an institution control the damage from these cases? What is on the horizon? How to gauge the impact on reputation? Is there a way to mitigate the harm that these actions cause to an institution? What is the role of the regulatory agencies when the Department of Justice and an agency such as the Drug Enforcement Administration or the Federal Bureau of Investigation are the driving forces in the cases? Is there any way to convince the Department of Justice that the actions against the financial institution should not be brought?
These are some of the questions that institutions must ask now that the Department of Justice, after several years of relatively little activity in the AML field, emerges as a major player. In this crucial pre-conference workshop, you will hear from experts who understand these cases. They will guide you on how to deal with them and on the many aspects you must confront and deal with now.
Instructors: Greg Baldwin, Mia Levine, Michael McDonald
Workshop B: Core Training Part I: Money Laundering and the U.S. Requirements – The Operation and Global Application of the Bank Secrecy Act and Its Regulations
If you operate or do business in the United States, home of the most aggressive and punitive money laundering regulatory scheme in the world, you must know the regulations, how they affect you and how to comply. This is true whether you work in banking, securities, money transmitting, mutual funds, insurance or a government agency. If you do not know these regulatory duties, the consequences can be devastating.
This workshop is the first in a two-part series designed to help you understand the U.S. Bank Secrecy Act and its regulations, as amended by the USA Patriot Act.
Whether you are new to the money laundering field, or a veteran who needs a refresher of these important requirements, you should not miss this workshop. You will learn how the 76 BSA regulations - which cover the full range of 25 or so industries covered by the BSA - affect everything from currency transaction reporting to the required elements of customer identification and anti-money laundering programs. Here, you will receive expert guidance and instruction on what the United States regulations are, including those of the Office of Foreign Assets Control (OFAC), how they work and to whom they apply. Acquire the basic know–how you need to effectively manage risks and safeguard your institution. Attend this workshop and learn how to keep your organization compliant and your career on an upward swing.
Part II of this Core Training series will teach you how the potent U.S. criminal money laundering and forfeiture laws work and how they apply to you today.
Workshop C: How You Can Deal Effectively With ‘Cover Payments’ to Avoid AML and OFAC Sanctions Risks
Recent enforcement actions highlight regulatory concerns about the use of cover payments by international financial institutions. Cover payments are funds transfers that involve two distinct payment message streams, which often do not identify the originator and beneficiary of the transfer in the payment order sent to correspondent banks involved in the payment. This practice exposes banks to the risk of unwittingly facilitating the international movement of money destined for illegal purposes or for the benefit of a person listed on a sanctions list of the European Union, OFAC or another body. The payments not only mask the involvement of sanctioned parties, but also prevent institutions from adequately monitoring for and reporting suspicious activity.
This pre-conference workshop explores, through the instruction of top experts, how institutions should manage the risks in cover payments and what information–gathering procedures they should use to minimize those risks.
Instructors: Hank Grant and Tim White
Workshop D: Core Training Part II: Money Laundering and the U.S. Requirements – The Money Laundering Laws and the Major Regulatory Enforcement Role of the U.S. Department of Justice
The U.S. money laundering laws are the most powerful and far-reaching in the world. Over the years since they were first enacted in 1986, the U.S. Congress has increased their coverage, reach and scope, making them the broadest and strongest money laundering laws worldwide. With "extraterritorial" provisions and court–imposed "willful blindness" doctrines, the laws represent the most lethal risk that you or your institution anywhere in the world can face.
The USA Patriot Act broadened the scope of the law to include a wider range of financial wrongdoing, including foreign public corruption proceeds and terrorist financing, as prosecutable offenses. Knowing how these laws work is crucial to the success of the money laundering controls at your institution. It is surprising that many financial institutions do not cover the ins and outs of legislation in their AML training.
This workshop is your chance to remedy that training gap and to hear top experts teach you how the law works, how U.S. government investigators and prosecutors can use it against you and your institution, and how to avoid becoming the target of a criminal money laundering investigation. You will learn how these laws reach persons and transactions around the world and how the U.S. government can seize accounts, money and other property that are tied to the criminal activity.
Registration Conference Bag ID Tags Courtesy of GlobalVision Systems
Lanyards Courtesy ofFircosoft Name Badges Courtesy of Complinet Room Key courtesy of WorldCheck
7:30 AM – 7:00 PM
Exhibition Hall Hours
7:30 AM – 8:30 AM
Continental Breakfast in Exhibition Hall Courtesy ofSafe Banking Systems
8:30 AM – 9:00
AM
Opening Remarks
9:00 AM – 10:15 AM
General Session
Section 1956(b) – The U.S. Justice Department’s Rediscovered Weapon That Blends Regulatory Mandates With a Prosecutor’s Wallop
The United States money laundering law gives the U.S. Justice Department a unique choice in dealing with financial institutions and others that help launder crime proceeds. It may prosecute them for money laundering, subjecting them to fines, loss of license and prison terms. Or, by a rare alternate route, it may sue them for all the money they allegedly helped their customer to launder. Last used against a bank in 1998, this “civil penalty” provision is now aimed at two institutions in New York U.S. federal court, Lloyds TSB Bank and Bank of Cyprus, for the record sums of $130,000,000 and $162,000,000. Prosecutors say the banks knowingly helped their customers launder the proceeds of a securities fraud that swindled thousands of investors in a publicly-traded company. The cases set important precedents for regulators, prosecutors, banks, securities dealers and insurance companies and underscore the consequences of doing business with persons who move dirty money through their accounts. In this session, money laundering warriors explain how this potent weapon works, how it reaches around the globe and how it can apply to you and your institution.
Panelists: Lewis Freeman, Gordon Greenberg, Laura Stuber, Richard Weber Moderator: Charles Intriago and Teresa Pesce
10:15 AM – 10:45 AM
Refreshment Break in Exhibition Hall Courtesy ofWolters Kluwer Financial Services | PCi
10:45 AM – 12:00 AM
General Session
Interpreting AML Enforcement Actions – Do They Hold Messages for All, as Examiners and Consultants Say, Or Are They Narrow Negotiated Settlements?
In the last two years more than $180 million in money penalties were imposed on a handful of banks and other institutions in the U.S. for AML and Bank Secrecy Act violations. Several more are coming. How important are these actions? Are they just byproducts of regulatory negotiations? Some field examiners and consultants say the orders carry doom and gloom lessons for all. While these cases hog headlines, dozens more non-public regulatory actions receive no publicity. The agencies even decline to reveal how many there are, including “Matters Requiring Attention,” “Supervisory Letters,” and “Memoranda of Understanding.” There, resolution is amicable and no penalties flow. What is the reality? What lessons do public actions really contain? Do they provide insight into how regulators think and what their priorities are? Do they serve for employee training on what went wrong at an institution? Here, experts answer these questions and decipher enforcement actions for your maximum utility. They tell you how you should use them even if you work at a non-bank financial institution.
Panelists: Herbert Biern, Hal Crawford, Mia Levine, Rick Small Moderator: John Byrne
12:00 PM – 1:30 PM
Luncheon
1:30 PM – 2:30 PM
Concurrent Sessions by Track
The New Convergence - How Smart Institutions Blend Data Pools and Systems to Combat Money Laundering and Fraud
In recent years many financial institutions that grapple with the challenge of complying with anti-money laundering laws and regulations and with deterring money laundering have been exploring the similarities of that effort with the hunt for fraudsters. What they have discovered is that there are resources, practices and tools that are used in one of those pursuits that can be used by the other. They have learned that the pursuit of launderers and fraudsters should not run on parallel tracks. Rather, they should tap the data pools and fraud indicators for elements that may assist in detecting money launderers and their schemes. Here, experts show you what you can do to get the best return on investment from your AML and fraud detection programs and how to capture the synergies and common elements that lie in both programs.
Panelists: William Langford, Ron King, Jane Ogden Moderator: Barry Koch
Realities and Myths of the AML Requirements in Supposed High-Risk Countries Colombia, Mexico, and the Dominican Republic
In designing a risk-based AML program, institutions are told to rate the risk in customer transactions and accounts from certain countries. A key element in determining this risk is the existence of a country’s sound AML regulatory regime. Drug trafficking, money laundering and other crimes have earned Colombia, Mexico and the Dominican Republic a “high risk” categorization. What is the regulatory landscape there? Are their financial intelligence units active and effective? Do they require registration or licensing of money services businesses? Are parallel foreign exchange markets illegal? What are the typical AML compliance programs and reporting requirements? In this panel, experts tell you the realities and dispel myths of the requirements in these countries to help you reach an accurate assessment of the country risks.
Panelists: Jorge Guerrero, Maria Elena Plata, Luisa F. Vargas Moderator: Michael McDonald
Unique AML Compliance Challenges Small Financial Institutions Face and How They Can Meet Them
In the United States, according to the Federal Deposit Insurance Corporation, there are 8,600 financial institutions, of which more than 7,000 have assets of less than $300 million. These smaller institutions face the same stringent anti-money laundering requirements as do larger ones but lack the resources and technology that their bigger counterparts have. What can the small bank and non-bank financial institutions, like money services businesses, insurance companies and jewelers, do? How can they build a risk-based program, obtain necessary expertise, and perform the sophisticated screening and monitoring implicit in the regulations? Here, experts guide the “little guy” and give practical advice on how to fend off AML dangers when budgets and asset size make it impossible to play in the same compliance league as the big wealthy neighbors across town.
Panelists: John Atkinson, Lorenzo Delzoppo, Jeff Sklar Moderator: Jim Richards
Avoiding Common Audit Deficiencies by Learning to Identify Problems in Audit Programs Before Regulators Do
The independently testing of the effectiveness of your anti-money laundering program is not just a good idea, it is a clear and explicit requirement that is hard-coded in the regulations of the United States and many countries. After years of practice and experience, audit deficiencies continue to be one of the top five issues that are found in regulatory enforcement actions and examination reports in the United States. Why do regulators have little confidence in auditor competency and audit reports? What are the boundaries between “compliance review” and “auditing”? What does “independent” mean and what grey areas merit attention? This panel of experts will explain where institutions are going wrong and what you can do to identify problems in your audit function before trouble heads your way.
Panelists: Brigitte Lowe, Jack Sonnenschein, Teresa Pesce Moderator: Alan Abel
2:30 PM – 2:45 PM
Time to Move to Next Concurrent Session
2:45 PM –3:45 PM
Concurrent Sessions by Track
Leading Practices Institutions Should Follow for Successful Transaction Monitoring and Reporting
Automated software systems are part of an effective transaction monitoring equation. The human element, good training and the capture of the right data are other crucial components of a good monitoring program. Banks and other financial institutions expect transaction monitoring to become their largest compliance expense in coming years. That makes it crucial to derive the most out of systems and procedures. Equally important is the effective analysis of data outputs and case management to obtain information that is necessary to identify suspicious activity. Experts on this panel guide you on leading and effective practices, how to evaluate systems to ensure a good return on investment, and how to maximize the quality of data your system provides for better investigative and reporting leads.
Panelists: John Byrne, Darren Donovan, John Wagner Moderator: Barry Koch
The Implications for Global Financial Institutions Under the New European Union Money Laundering Directive
The Third European Money Laundering Directive took effect on December 15, 2007, imposing in some respects tougher provisions on European financial institutions than those faced by their global counterparts. The Directive expanded its coverage to new industries and professions, including lawyers, accountants and real estate agents, and imposed comprehensive beneficial ownership disclosure requirements. AML experts say global institutions should look at these standards as leading practices and incorporate them. How does the Directive affect your AML compliance program? What challenges do EU institutions confront in implementing the provisions of the Directive? Here, you get answers to these questions and discover out the implications of the Directive for your institution.
Panelists: David Bagley, Jane Ogden, Waheed Rathore Moderator: Martin Feuer
How U.S. Insurance Companies Should Prepare for AML Examinations by the U.S. Internal Revenue Service
U.S. life insurance and annuities companies are now subject to Bank Secrecy Act requirements to maintain an AML program and report suspicious activities. They face challenges such as the lack of a federal functional regulator and significant reliance on independent agents, who sell their policies but are not “captive” agents. The industry has struggled with how adequately to implement the requirements with little guidance from the Internal Revenue Service, which has the task of supervising compliance by insurance companies. Last year, the IRS began training new AML examiners to supervise the industry. And, it conducted the first fourteen examinations of life insurers. How are they being conducted and what should life insurers expect? How can they assure their AML programs meet regulatory requirements? Here, insurance AML experts and a senior IRS examiner guide you on best practices.
Panelists: Michael De Luca, Molly Possehl, David Tilzer Moderator: Brian Ferrell
Monitoring and Deciphering Foreign Exchange Transactions to Insulate Your Institution from Penalties and Money Laundering Risks
The Black Market Peso Exchange has been a target of law enforcement since the early 1980s as it pursues drug money laundering. This campaign is reflected in the several recent “Deferred Prosecution Agreements” and regulatory actions against major U.S. banks that failed to monitor the activities of foreign currency exchangers. The bank accounts of casas de cambio continue as targets of U.S. enforcement agencies and regularly seized while their owners are named in drug and money laundering cases. This panel will provide training for banks on monitoring and analyzing the accounts of international dealers in foreign exchange to identify potential money laundering risks, especially in BMPE transactions. You will be guided on enhanced due diligence that will help you manage these accounts and on how to respond to suspicious activity.
Panelists: Alex Seddio, Natasha Pankova Taft Moderator: Michael McDonald
3:45 PM – 4:15 PM
Refreshment Break in Exhibition Hall Courtesy of Deloitte Financial Advisory Services LLP
4:15 PM – 5:15 PM
Concurrent Sessions by Track
How to Build Solid Training Programs Tailored to Employee Roles and Business Lines
In recent enforcement actions against banks, regulators have underscored the importance of tailoring AML training to the roles of employees at financial institutions. From C–Suite executives to tellers, it is crucial that institutions determine the type of training employees in different departments and business lines need. By addressing the responsibilities and roles of employees, institutions may reduce training costs, ensure that employees learn what applies to them and maximize effectiveness in identifying and preventing money laundering. How do you determine the type and frequency of employee training? How do you tailor training to specific business lines? Here, experts who take a tailored approach to training guide you on creating an AML training program that will not come under regulatory criticism.
Panelists: Harry Abou-El-Fotouh, Barry Koch, Brigitte Lowe Moderator: Charles Intriago
How Money Services Businesses Can Enhance AML Programs With Good Transaction Monitoring and Testing
Since 2000, money services businesses have made great strides in developing and implementing sound AML compliance programs. Transaction testing is a crucial part of a sound program. It is an important tool for MSBs and their independent reviewers to determine how effective their AML program is and to ensure that its standards are met. This panel will teach you best monitoring practices, how to create transaction reports to monitor for unusual or suspicious activity, and how to test transactions for overall compliance. Compliance officers at money services businesses will learn from seasoned experts how to enhance their programs. Independent reviewers will learn how to conduct program tests and document results. And, bank compliance officers will gain insight into the monitoring practices of MSBs and the daily application of their AML programs.
Panelists: Jorge Guerrero, Jeff Sklar, David Tilzer Moderator: Michael McDonald
Mastering Spreadsheets to Bring Your AML Investigations, Due Diligence and Compliance to Higher Levels
This eye-opening session showcases Jim Richards, who will show you how Excel® and other spreadsheets, everyday tools already at your disposal, can help you conduct daunting anti-money laundering tasks quickly and efficiently. From creating a risk assessment to analyzing customer transactions and conducting investigations, Richards will teach you how you can maximize the often underutilized features of Excel® and other spreadsheets software. You will be surprised at the many ways in which you can apply this tool to your everyday AML work. Learn the insider’s tips and tricks that Richards has uncovered over the years and take away new techniques that will increase your productivity and save you money. You will not want to miss this fast–paced, entertaining session.
Panelists: Jim Richards Moderator: Tim White
5:30 PM – 7:00 PM
Cocktail Reception
7:15 PM - 8:15 PM
Dessert Reception for ACAMS Members Courtesy of the Association of Certified Anti-Money Laundering Specialists (ACAMS)
Continental Breakfast in Exhibition Hall Courtesy ofRegulatory DataCorp International
8:00 AM – 9:00 AM
AML Knowledge Breakfasts
AML Knowledge Breakfast Courtesy ofCrowe Chizek Leading Practices for Streamlining Your AML Program
The most recent 2007 results of the ABA Banking Journal's and Banker Systems last survey continue to conclude that Bank Secrecy Act / AML / OFAC is the top banking industry compliance area in terms of cost. Institutions continue to dedicate considerable resources to meet ever expanding regulatory requirements and expectations. Compliance infrastructure and reviews, risk assessment processes, transaction monitoring, analysis, reporting and testing -- these investments and processes continue to stretch the resources of institutions of all sizes.
This session describes proven steps that institutions can take to drive down the costs of their AML compliance efforts while building a sound program that meets their supervisors' expectations. This session will provide practical examples of how other organizations have developed leading edge practices and implemented policies, risk-based procedures and supporting technologies to deliver an effective solution to this growing challenge.
Panelists: Alan Abel and Brian Kloostra
AML Knowledge Breakfast Courtesy ofDun & Bradstreet, Inc. Solving the Puzzle of Better Customer Identification: The Benefits of a Non-Documentary Approach
Customer identification is challenging for many institutions. In this dynamic session we’ll share a simplified approach to using non-documentary activities to improve customer identification. We’ll discuss enhanced techniques and industry best practices for using independent third party business information for non-documentary activities. You’ll learn how you can reduce the document collection burden for both customers and staff to streamline your on-boarding process, gain additional business insight, and simplify your customer monitoring process. Using this non-documentary approach also gives you a head start on your customer risk assessment activity, which can lead to more profitable customer relationships.
Panelist: Keith Webster, AVP of Business Development for Enterprise Risk & Compliance, Dun & Bradstreet Inc
AML Knowledge Breakfast Courtesy of PricewaterhouseCoopers Deriving Sustainable Efficiencies Out of Your AML Investments
Most AML remediation programs represent a significant investment on the part of the institution resulting in new processes, procedures, policies, technologies, people and programs. We will discuss how you can sustain the improvements in your AML programs across the enterprise on an ongoing basis to help you protect your hard earned brand and reputation.
Panelists: Catherine Stahlmann, Director; Monique Moranto, Director; Rei Tanaka, Director Moderator: John Campbell, Partner Pricewaterhouse Coopers
9:00 AM – 10:30 AM
General Session
Why Should Only Presidential Candidates Have Debates? We Take Your Hottest Questions and Moderator Jim Richards Fires Them to Top Experts Onstage Who Face Off on the Answers
It’s an election year in the United States so why not emulate the candidates and give you a lively, free flowing interchange among top experts, moderated by Jim Richards? We will videotape questions from the audience or take them live and Jim will fire them to members of the panel and make sure they give straight answers and guide you on how to do your job better at a financial institution or a government agency. To make it more enriching for you, later we will upload on a special conference page at moneylaundering.com, all materials, cases and documents the experts mentioned in the “debate.” We will also let you see the session again by uploading a streamed video of this “debate.” This no-holds-barred panel will challenge the experts to answer your hottest questions. Jim Richards will keep it lively and make sure you get insight and guidance on the pressing AML and terrorist financing issues of the day.
Panelists: John Byrne, Lester Joseph, Michael McDonald, Rick Small Moderator: Jim Richards Time Keeper: Charles Intriago
10:30 AM – 11:00 AM
Refreshment Break in Exhibition Hall Courtesy of BANKDetect, LLC
11:00 AM – 12:15 AM
General Session
How Chief Compliance Officers Leverage BSA/AML Duties Into Overall Compliance for Greater Efficiency and Effectiveness
Chief compliance officers sit at the pinnacle of responsibility for institutional compliance with laws and regulations. While AML and Bank Secrecy Act compliance are the most visible and risk-laden of their responsibilities, they have much more to worry about, Sarbanes-Oxley and corporate governance included. Facing budgetary pressures and increasing regulatory enforcement, CCOs are under pressure to achieve efficient, effective and economical practices that provide maximum protection in overall compliance. They seek optimal ways to integrate the various compliance responsibilities into an overall compliance program that achieves efficient synergies. How to do that effectively and productively? How to leverage existing systems? How to achieve economies of scale in compliance? What lessons can one area of compliance teach another? Is the use of fraud detectors and data pools being maximized to combat money laundering? These are some of the questions that confront a CCO daily. Here, three top CCOs and a former senior Federal Reserve supervisory officer guide you on best practices in these crucial undertakings.
Panelists:David Bagley, Herbert Biern, Jefferey Reitman, Lena Stinson Moderators: Charles Intriago and Dan Soto
12:15 PM – 1:45 PM
Luncheon Courtesy of Norkom
1:45 PM – 2:45 PM
Concurrent Sessions by Track
Managing the AML Risks of Correspondent Banking and Meeting the Regulatory Requirements of USA Patriot Act Section 312
Financial institutions with correspondent accounts in the U.S. face costly due diligence duties under the USA Patriot Act Section 312 rules. U.S. banks, broker–dealers and mutual funds must exercise special due diligence on international institutions with correspondent relationships. Some non-U.S. financial institutions face stricter demands from their U.S. counterparts. U.S. institutions must corroborate the adequacy of the AML programs of their foreign correspondents. Failure to comply can lead to hefty penalties and bad publicity. To avoid this and to reduce the costs of compliance with these requirements, some institutions have discontinued their correspondent accounts. Here, experts guide you on the steps you should take to mitigate the risks of correspondent banking and on how non-U.S. institutions can manage the growing demands of their U.S. correspondents.
Panelists: Lisa Arquette, Hal Crawford, Maria Odegbaro Moderator: Teresa Pesce
How to Address and Administer the Unique Challenges That Islamic Banking and Its Products Pose
Islamic banking generates profit by pooling and investing client deposits in order to comply with Shari’a (Islamic) law. Financial institutions that follow Shari’a law can be viewed as being a lower money laundering risk because they must ensure that funds are not derived from an illegal source and are involved in the daily administration of financed assets. As Western institutions expand into Islamic banking, how should they adjust their AML procedures to assess the risks in the new products they offer? How should their monitoring processes change? What myths should be dispelled concerning Islamic banking products? What do regulators and Western financial institutions need to know? Here, you will receive guidance on best practices in dealing with Islamic banking and its products. You will also learn what to do in customer due diligence, special transaction monitoring and how to assess the risks of Islamic finance products.
Panelists: Hany Abou-El-Fatouh, David Bagley, Waheed Rathore Moderator: Charles Intriago
What Every Insurance Company Must Know About OFAC Compliance and To Whom It Extends
The rules of the U.S. Office of Foreign Assets Control, which impose sanctions and require the blocking of funds and accounts of “designated” persons, countries and institutions, apply to all U.S. persons and corporate entities, including insurance companies. The rules present unique challenges and compliance requirements for the insurance industry. What are they and how do OFAC rules apply to insurance products? If you provide group coverage to an organization must you screen against OFAC sanctions lists all persons associated with the group? How do you monitor source of payment on policies? When and how often should you screen OFAC lists? What are the OFAC compliance issues for named beneficiaries of your policies? This panel of experts helps you answer these questions and guides you on assuring a sound OFAC compliance program.
Panelists: Brian Ferrell, Martin Feuer, Molly Possehl Moderator: Tim White
Plastics and E-Cash: The Money Laundering Dangers of Emerging Technologies and How to Detect Them and Combat Them
The proliferation of electronic payment systems and new payment products poses complex AML challenges and risks for compliance professionals and law enforcement agents. Virtual worlds – games that allow millions of users to conduct real-life activities online using digital currencies that can easily be converted into real cash – are growing exponentially. So is the use of other electronic payment systems like stored value cards and mobile remittances. The ease of use, pervasiveness and anonymity of these systems and the little-to-no regulation they face, make them attractive avenues for criminal abuse. In this panel, learn from top industry and government experts about the uses and abuses of these products, how they work and what AML measures financial institutions can employ to guard against illegal activity using these products.
Panelists: John Atkinson, Natasha Pankova Taft, Colleen Piccone Moderator: John Byrne
2:45 PM – 3:00 PM
Time to Move to Next Concurrent Session
3:00 PM – 4:00 PM
Concurrent Sessions by Track
How to Improve the Quality of Your Suspicious Activity Reporting Program
Financial institutions know that a sound suspicious activity detection and reporting system is one of the key pillars of self-protection. Yet years after SAR reporting duties took effect, deficient suspicious activity reporting practices continue appearing in enforcement actions and government reports. The U.S. Financial Crimes Enforcement Network last year cited incomplete information and poorly written narratives as the most common problems it finds in the hundreds of thousands of SARs it receives each year. How can institutions identify deficiencies in their programs? How can one achieve top quality SAR reporting? In this panel, industry experts teach you how to improve the quality of your program, how to train your employees in the proper filing of SARs and how to assure quality in your SARs before they reach the regulators.
Panelists: Michael De Luca, Barbara Keller, Maria Odegbaro, Don Temple Moderator: William Langford
Mitigating the Risks of Money Laundering Through International Trade By Sound Risk Profiling and Monitoring
The manipulation of international trade prices and other trade-based laundering activities enable the movement of criminal proceeds through international commerce. A 2006 study by the Financial Action Task Force identified trade as an increasingly important channel for criminal activity. The 2007 U.S. interagency examiners’ manual clarified regulatory expectations about trade finance products. The heightened attention the issue has received from governments and international bodies has added pressure on financial institutions to scrutinize trade financing and transactions. The involvement of multiple parties and often complex financing arrangements in trade transactions make this a costly, difficult task. Here, experts teach you how to profile trade transaction risks, how trade is used for money laundering and what to do to mitigate the risks.
Panelists: Colleen Piccone, John Wagner, John Zdanowicz Moderator: Barry Koch
Successful Strategies for Managing Agents and Foreign Paying Representatives of a Money Services Business
Sting operations in New York and the pursuit by U.S. law enforcement of casas de cambio in high-risk countries highlight the need for sound management practices of MSB agents, at point of sale locations and companies that pay remittance orders in the country of the beneficiary. Constructing and maintaining sound and complete files for agents and correspondents or the foreign paying agents is an essential element of an MSB’s compliance program. What does this mean? What should be included? What should money remitters build into their AML program to provide a sound foundation for agent and correspondent management? What do banks expect? How far must you go to protect your MSB, your banking relationships and your industry? Hear from industry experts and learn how to comply with regulatory responsibilities in handling foreign agents and counterparties.
Panelists: Jorge Guerrero, Tom Haider, Peter Ziverts Moderator: Jeff Sklar
Using the (Free) Web to Improve Your Money Laundering Defenses and AML Due Diligence
Back by popular demand, this engrossing and enriching panel led by Jim Richards unveils the millions of hidden treasures of the Web. Richards shows you how the Web can be your close ally in conducting AML due diligence and investigations, saving you substantial time and money in hiring outside investigators and experts. Learn how to navigate the bountiful but little-known and newly discovered recesses of the Web, such as the “invisible web” and the “historical web,” and discover powerful tools and resources available to everyone. Learn how to get better search results, where to find public records, how to do research on your customers and much more. Richards teaches you how the World Wide Web is an invaluable and inexpensive tool in money laundering controls.
Panelists: Jim Richards Moderator: Dan Soto
4:00 PM – 4:30 PM
Refreshment Break in Exhibition Hall Courtesy of Cellent Finance Solutions AG
4:30 PM – 5:30 PM
Concurrent Sessions by Track
Effective Due Diligence Strategies for High-Risk Customers, Accounts and Products
Applying the correct level of due diligence to customers, accounts and products is crucial to avoiding running unnecessary risks. Politically exposed persons, offshore accounts and certain products such as prepaid cards are considered high-risk. Before doing business with them, institutions must determine the level of due diligence they should apply and the steps they should take to scrutinize these customers, accounts and products. Determining the type and frequency of due diligence can be confusing and costly, especially if the institution is dealing with products, customers or transactions that do not fit into classical definitions of high-risk. Here, you will learn how to determine what level of due diligence the riskier areas of your business require and how to scrutinize and monitor them to protect your institution.
Panelists: Jane Ogden, Jack Sonnenschein, Laura Stuber Moderator: Charles Intriago
Building a Top Quality Insurance AML Training Program for Employees and Agents
For U.S. insurance companies the ongoing training requirement that is part of their anti-money laundering program duties poses a unique challenge. Under the Bank Secrecy Act regulations, they must train their employees and also the independent agents and brokers that sell and distribute their products. Insurance companies have struggled with finding the best method of providing independent agents with AML training while not losing their patronage. What best practices have emerged in the AML training field for life insurers and the independent agents? What is effective training for the agents? What should the content of the training be? How does a company verify that agents have been trained? Here, industry experts show you how to construct and administer a successful insurance AML training program.
Panelists: Brian Ferrell, Lisa Tate, David Tilzer Moderator: Martin Feuer
Tailoring Your Audit Program to Meet the Needs of Your Institution and Satisfy Regulators
The independent audit process required by the U.S. and most national AML regimes can shed much light on the money laundering preparedness of an institution and how well it is fulfilling regulatory and internal requirements. An independent source can help the institution determine whether it is performing as required by regulation and as the institution envisioned. To have a successful audit program the institution must meet its risk management needs and the concerns of the examiners. What are the key ingredients to do this? How do you set the scope of your audit program? How do you test program design versus effectiveness? In this panel, experts will teach you what the key elements of a successful audit program are and how to tailor it to adequately meet the needs of your institution.
Panelists: Alan Abel, Hany Abou-El-Fotouh, John Atkinson Moderator: William Langford
AML Knowledge Breakfast Courtesy of IBM Corp. Avoiding the new Wave of AML Fines by Knowing the People Behind the Transactions
Can your existing AML system differentiate between the accounts of multiple people vs. accounts of a person using multiple identities? Detect networks of people working together? Are you concerned about reputation damage should you inadvertently be assisting with funding of international crime? Do you need to better understand names, and their many variations, from languages, cultures and regions around the world? For businesses as well as individuals? Join us at this session to learn more about the IBM AML solution that can address these issues now in your financial institution.
9:00 AM – 10:15 AM
General Session
Has the Risk-Based Approach Begun to Outlive its Usefulness and Is It Effective?
The risk-based approach to money laundering controls has gained traction globally in recent years. Last year, the Financial Action Task Force issued guidance co-written by this session’s moderator, Rick Small. The European Union adopted the approach in its Third Money Laundering Directive. The most recent interagency U.S. Examination Manual expanded coverage of the risk-based approach to AML controls. Financial institutions agree that the approach is effective in combating money laundering. But, with the number of specific rules that institutions must follow and with regulators who sometimes appear more concerned about ‘check-the-box’ compliance than effective overall controls, can a risk-based approach work? Should institutions apply a risk-based process or adopt a rules-based approach? In this lively session, top experts show how to balance the two approaches and what to do for maximum protection of your organization in assessing money laundering risks.
Panelists: Lisa Arquette, Hal Crawford, Brian Ferrell, William Langford Moderator: Rick Small
10:15 AM – 10:45 AM
Refreshment Break in Exhibition Hall
10:45 AM – 12:00 PM
General Session
The Growing Influence of OFAC, EU and UN Sanctions Programs and the Best Practices You Should Adopt for Compliance Excellence
Compliance with the regulations of the U.S. Office of Foreign Assets Control and the sanctions lists of the European Union and the United Nations has risen recently in visibility and importance as the world attempts to choke off terrorist funding and the movement of drug trafficking billions. The sanctions lists of OFAC, the European Union and the United Nations are not identical; nor are the procedures for inclusion of names of persons or organizations identical for the three lists. What are the best practices for complying with OFAC and other sanctions programs? What employee training programs will improve compliance with OFAC and other sanctions programs? Are there non-commercial sources of information that provide compliance help? What lessons can be learned from enforcement actions against financial institutions for OFAC violations? In this panel, experts help answer these questions and guide you on best practices in the sensitive field of OFAC and sanctions compliance.
Panelists: David Bagley, Hank Grant, Tom Haider, Tim White Moderator: Charles Intriago
