Recent BSA/AML Trends and Developments: Best Compliance Practices for Your Client
As threats of financial crimes continue to grow, enforcement actions under the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) remain to have a significant impact and implication on future regulations. Recently, the Office of the Comptroller of the Currency (OCC) released its 2020 bank supervision operating plan that sets forth its supervisory strategies and objectives regarding BSA/AML compliance. Through the plan, the agency asserted its priority on customer due diligence and beneficial ownership, specifically by “determining whether BSA/AML risk management systems match the complexity of business models and products offered, evaluating technology solutions to perform or enhance BSA/AML oversight functions, and assessing the adequacy of suspicious activity monitoring and reporting systems and processes”.
These changes provide a crucial need for financial institutions to update and enrich their AML program, meet compliance obligations, and avoid potential risks and pitfalls.
In this LIVE Webcast, regulatory compliance experts, Susrut Carpenter (BakerHostetler) and Maureen Kiedaisch (FTI Consulting), will present an in-depth review and analysis of the recent trends and developments in the BSA/AML landscape. They will provide the audience with practical tips and best compliance strategies in ensuring maximum compliance in the midst of a rapidly evolving legal climate.
Some of the major topics that will be covered in this course are:
- Overview of BSA/AML Bank Supervision Operating Plan
- Recent Trends and Updates
- Legal Risks and Issues
- Practical Tips and Strategies
- Best Compliance Practices
- What Lies Ahead
Susrut A. Carpenter, Counsel
Baker & Hostetler LLP
- BSA/AML regulatory enforcement trends spawn changes in the compliance landscape: A brief discussion on the new DOJ Compliance Guidelines and the OCC Bank Supervision Operating Plan. The new requirements will lead to changes in how regulated entities engage in compliance.
- Compliance guidelines: 3 main questions to consider in creating a BSA/AML compliance program
- OCC Plan: Enhance suspicious activity monitoring and BSA/AML oversight functions through technology
- One key issue in complying with BSA and AML regulations is the quagmire of information sharing (314(b)). Understanding this and its importance would aid in better compliance programs and increase efficiency in enforcement.
- The main laws involved in BSA/AML enforcement:
- Money Laundering Laws
- Enforcement Agencies: DOJ, SEC, FinCEN, OCC
- Case examples of BSA/AML regulatory actions and the related compliance failures
- General key elements of BSA/AML compliance program
- Establishing internal controls and policies and procedures to assure ongoing compliance
- Ensuring independent testing of an AML program at a scope and frequency that matches current risk assessment (Risk assessments discussed in detail by Maureen Kiedaisch)
- Training personnel in, among other things, the identification of unusual financial transactions and aggregation of currency transactions
- Designating an individual responsible for assuring day-to-day AML compliance
- Providing adequate resources to compliance functions
Maureen Kiedaisch, Senior Managing Director
- Recent BSA/AML regulatory developments and trends underscore a persistent focus on risk-based approaches, automation and tech solutions, and data quality and integrity
- These developments and trends point to a need for comprehensive risk assessments – the foundation for strong BSA/AML compliance programs
- Financial regulators consistently cite risk assessments as the most common BSA/AML compliance deficiency
- Presentation on best practices for BSA/AML risk assessments, covering:
- An overview of essential components and framework
- Who should be involved in the assessment process
- Types of data that should be utilized
- How often/when these should be conducted
- Potential solutions to key challenges associated with conducting such assessments (e.g. costs, resources, data, complexity)
Who Should Attend:
- Banking and Finance Lawyers
- Anti-Money Laundering Lawyers
- AML/BSA Compliance Managers and Officers
- Financial Reporting Officers
- Financial Auditors
- Finance Executives
A trial lawyer and former prosecutor, Sonny Carpenter is a member of BakerHostetler’s National White Collar, Investigations and Securities Enforcement and Litigation team. He focuses his practice on internal investigations, white collar defense, and regulatory compliance matters, specifically in the areas of healthcare, securities, corruption, and money laundering.
A trial lawyer and former prosecutor, Sonny Carpenter is a member of BakerHostetler’s National White Collar, Investigations and Securities Enforcement …
Maureen Kiedaisch is a Senior Managing Director at FTI Consulting with more than 25 years of experience in the banking industry, which included operations, compliance, administration, management, and employee development. Ms. Kiedaisch established, reviewed, and implemented various policies, procedures, internal controls, and work programs as well as designed and documented process workflows. Ms. Kiedaisch reviewed audit/exam findings and designed programs to ensure necessary corrective actions were implemented. At FTI Consulting, she focuses her practice in the financial services industry providing clients with regulatory compliance, Bank Secrecy Act/Anti-Money Laundering/OFAC compliance and operations-related services. Ms. Kiedaisch has worked on matters related to supporting banks develop a policy and procedure framework as well as a governance structure. In addition, she has worked on several BSA/AML reviews and has extensive experience developing compliance and BSA/AML policies and procedures, performing risk assessments and evaluating and implementing internal controls.
Maureen Kiedaisch is a Senior Managing Director at FTI Consulting with more than 25 years of experience in the banking …
Print and review course materials
Method of Presentation:
General knowledge of banking and finance laws
NY Category of CLE Credit:
Areas of Professional Practice
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About Baker & Hostetler LLP
Recognized as one of the top firms for client service, BakerHostetler is a leading national law firm that helps clients around the world to address their most complex and critical business and regulatory issues. With five core national practice groups – Business, Employment, Intellectual Property, Litigation and Tax – the firm has approximately 1000 lawyers in offices from coast to coast. BakerHostetler is widely regarded as having one of the country’s top 10 tax practices, a nationally recognized litigation practice, an award-winning data privacy practice and an industry-leading business practice. Visit bakerlaw.com
About FTI Consulting
FTI Consulting is an independent global business advisory firm dedicated to helping organizations manage change, mitigate risk and resolve disputes: financial, legal, operational, political & regulatory, reputational and transactional. Individually, each practice is a leader in its specific field, staffed with experts recognized for the depth of their knowledge and a track record of making an impact. Collectively, FTI Consulting offers a comprehensive suite of services designed to assist clients across the business cycle – from proactive risk management to the ability to respond rapidly to unexpected events and dynamic environments.