Primary Course Objectives

• Identify and examine the major money laundering risks a financial institution faces
• Establish, implement, and enhance intenal controls, policies, procedures, and processes to meet relevant regulatory requirements and mitigate AML risk
• Identify, investigate, and properly report suspicious activity

Who Should Attend?

• BSA/AML Compliance Officers
• Consultants
• Bank Examiners
• Lawyers

Preparation

Participants should be employed in the financial industry.  Attendees are expected to complete a comprehensive pre-class reading list that will facilitate the successful completion of the exam. The reading list includes the most recent version of the FFIEC BSA/AML Manual, FinCEN and FATF advisories, and other relevant guidance. 

Anticipated reading time:  10-15 hours

Certification Exam

The online certification exam consists of 100 comprehensive questions that must be completed within 1 hour and 45 minutes.  Attendees passing the exam with 75% or higher will receive the prestigious FIBA AMLCA Certification. 

Registration fees

For more information contact, Fedra Ware at fedra@fiba.net or call 305-539-3796

The risks posed by correspondent banking are of concern to regulators, bankers, and broker-dealers in securities alike.  Recently,U.S.financial institutions have faced severe penalties as a result of having weak AML/BSA compliance programs for their foreign correspondent banking accounts.  The various sections of the USA PATRIOT Act and implementing regulations in the Bank Secrecy Act have been in final form for a number of years now.  This course will discuss not so much the regulations but rather the practical applications of the regulatory requirements, with a particular emphasis on nested accounts.

Course Highlights

Brief History and Regulatory Expectations
Definition of Correspondent Banking with a mention of foreign MSBs
Foreign Financial Institution Risk Rating Methodology

1. In depth discussion of items to consider for each risk factor

Due Diligence Program

1. General Due Diligence Considerations
2. Discussion of Nested Accounts and the Informal Value Transfer System and Offshore Intermediaries
3. Enhanced Due Diligence Considerations
4. On-Going Due Diligence Requirements
5. Certifications
6. Access to Records

Transaction Monitoring Program

1. Program Requirements with a Focus on the Review the following Transaction Types and the associated Red Flags

                     i.      Wire Transfers

                    ii.      International ACH

                    iii.      Bulk Cash

                    iv.      Cash Letter/ Pouch

                     v.      Remote Deposit Capture

                    vi.      Dollar Drafts

                    vii.      Trade Finance

Case Studies

1. Detailed Review of Enforcement Actions for Lessons Learned

Internet Gambling and Correspondent Banking

Name Screening

1. Section 311 – Special Measures
2. Bureau of Industry Standards (export control)
3. Office of Foreign Assets Control
4. Consequences of Sanctions Non-Compliance

                   i.      Lessons Learned

5. ComprehensiveIranSanctions, Accountability, and Divestment Act of 2010

Correspondent Banking BSA/AML and OFAC Contract Considerations

Advanced Preparation

Attendees are expected to review  a comprehensive pre-class reading list.

Anticipated time is 5 – 7 hours.  

Registration Fees

This course focuses on the specific responsibilities and challenges faced by managers and the board of directors. We will also review practical solutions and guidance which managers and directors can use as "best practices,” and which can serve as benchmarks to evaluate the AML/BSA compliance programs at their institutions. 

Outside directors face a special challenge in today’s regulatory environment. Directors may not have firsthand knowledge of their banks’ everyday operations because they are not employees. However, they are expected to be just as knowledgeable about the bank’s AML program, its effectiveness, and any potential problems as are management and the compliance department.

Regulatory issues are likely to occur if management does not fully understand its responsibilities.  Lack of sufficient management support, or lack of management understanding of its critical role, can lead to serious problems for the financial institution.

Course Content

• Defining money laundering & terrorist financing
• Global AML/CTF framework
• AML/CTF roles and responsibilities of boards of directors
• AML/CTF roles and responsibilities of senior management
• AML/CTF risk management
• Pillars of an effective AML/CTF program
• Know Your Customer
• Overview of customer risk rating
• Transaction monitoring
• Record retention
• Role of supervisors
• Sanctions program overview
• Anti-corruption efforts
• Top 10 AML deficiencies
• Consequences of non-compliance
• Protecting your financial institution

Oral Exam / Certificate of Completion

Participants will be required to successfully complete a short  oral group exam immediately following the training.  Participants will receive a certificate of completion after passing the test. 

Registation Fees