Ongoing reviews of high-risk customers have been required since FinCEN's first exam manual in 2005, and CDD/EDD guidance further defines how institutions should identify and evaluate them. Regulators, however, have not spelled out the day-to-day approach.
This 60-minute BSA/AML high-risk customer training fills that gap with practical steps to meet both the letter and the spirit of the rules. Drawing on real audit findings, it shows what many banks get wrong and what to do instead.
You'll review FinCEN, FATF and FFIEC requirements, what to include in your high-risk program, current issues, recent enforcement actions, and real-life review examples you can adapt.
WHY SHOULD YOU ATTEND?
Weak high-risk customer programs draw examiner and regulator criticism and enforcement actions. This session helps you identify existing and new high-risk customers properly, use internal knowledge efficiently and run reviews that add real value to your BSA program.
It suits front-line BSA/AML and account opening staff, BSA/AML and compliance officers, risk managers, auditors and consultants.
AREA COVERED
- Why institutions need information about high-risk customers
- FinCEN and FATF requirements
- FFIEC guidelines for determining high-risk customers
- FinCEN expectations for a good high-risk customer program
- Items to include in your high-risk program
- Matching written requirements with the spirit of the law
- Three common mistakes in identifying high-risk customers
- Current issues in the high-risk process
- Recent enforcement actions against weak high-risk programs
- Real-life high-risk customer review examples
LEARNING OBJECTIVES
- Explain FinCEN, FATF and FFIEC expectations for high-risk customers
- Avoid three common mistakes when identifying high-risk customers
- Make sure existing and new high-risk customers are identified properly
- Perform high-risk reviews that deliver real benefits to the BSA program
- Leverage internal resources and knowledge efficiently
- Avoid examiner and regulator criticism of high-risk customer reviews
- Understand the net effect of your institution's efforts
WHO WILL BENEFIT?
- Front line BSA/AML Staff
- Account Opening Staff
- Risk Managers
- BSA/AML Officers
- Compliance Officers
- BSA/AML Audit Staff
- Auditors
- BSA/AML Consultants
Weak high-risk customer programs draw examiner and regulator criticism and enforcement actions. This session helps you identify existing and new high-risk customers properly, use internal knowledge efficiently and run reviews that add real value to your BSA program.
It suits front-line BSA/AML and account opening staff, BSA/AML and compliance officers, risk managers, auditors and consultants.
- Why institutions need information about high-risk customers
- FinCEN and FATF requirements
- FFIEC guidelines for determining high-risk customers
- FinCEN expectations for a good high-risk customer program
- Items to include in your high-risk program
- Matching written requirements with the spirit of the law
- Three common mistakes in identifying high-risk customers
- Current issues in the high-risk process
- Recent enforcement actions against weak high-risk programs
- Real-life high-risk customer review examples
- Explain FinCEN, FATF and FFIEC expectations for high-risk customers
- Avoid three common mistakes when identifying high-risk customers
- Make sure existing and new high-risk customers are identified properly
- Perform high-risk reviews that deliver real benefits to the BSA program
- Leverage internal resources and knowledge efficiently
- Avoid examiner and regulator criticism of high-risk customer reviews
- Understand the net effect of your institution's efforts
- Front line BSA/AML Staff
- Account Opening Staff
- Risk Managers
- BSA/AML Officers
- Compliance Officers
- BSA/AML Audit Staff
- Auditors
- BSA/AML Consultants