Course Description:

The cost of non-compliance with regulatory BSA/AML standards within organizations has been great. Organizations have suffered irreparable reputational damage and have had to pay exorbitant regulatory fines in the millions for failing to implement and maintain strong compliance programs. It would be prudent to ensure your organization’s compliance program is effective and it is tailor-made in light of the key risk factors within your organization.

This seminar will provide an overview of the importance of the risk based approach in implementing and maintaining an enterprise wide compliance program.

This two day interactive workshop will also provide attendees:

  • The basis of the risk based approach and the essential elements of an effective risk assessment.
  • Transaction monitoring guidance, suspicious activity guidelines and independent testing techniques which would assist attendees in improving their companies overall compliance program.
  • A detailed review of enforcement action case studies and how these could have been prevented
  • Key internal controls that can help prevent and detect money laundering and terrorist financing
  • Best practice tools on how to implement and maintain an enterprise wide Risk Based Approach (RBA) compliance program within your organization
  • RBA Toolkit that will assist attendees to implement and maintain an effective enterprise wide compliance program

Learning Objectives:

Key goals of this course are:

  • To provide an understanding of the key elements of a risk based approach
  • To effectively mitigate the money laundering and other financial crime risk within your organization
  • To meet/exceed regulatory expectations and to ensure the organization is prepared to manage vulnerabilities of money laundering and other financial crimes
  • To understand the holistic nature of the risk assessment which takes into account all business lines of the organization
  • The course will focus on the following key aspects of an enterprise wide compliance program:
    • Policies and Procedures
    • Customer Due Diligence
    • Transaction monitoring guidance
    • Suspicious Activity Reporting guidelines
    • Ongoing Due Diligence
    • Adequate training
    • Independent testing techniques
    • Senior Management Oversight
  • To focus on the key internal controls that can detect and prevent money laundering and other financial crime
  • To discuss key case studies and how enforcement actions could have been prevented
  • The Foreign Corrupt Practices Act (FCPA)
  • The Office of Foreign Assets Controls (OFAC)
  • Bank Secrecy Act (BSA)
  • To review the key concepts and implementation steps of a risk based approach enterprise wide compliance program

This seminar will provide you answers to some of the most common challenges relating to compliance programs:

  • Are you struggling with the implementation and maintenance of an effective risk based enterprise wide compliance program?
  • Are you looking to improve the efficiency and effectiveness of your compliance program in light of limited resources?
  • Would you like to ensure that your company operates an effective AML/CFT program which meets or exceeds regulatory expectations and industry best practice standards?
  • Are your employees trained to critically identify and assess the impact new products and services will have on their overall risk assessment?
  • Is your company aware of its regulatory obligations and the potential impact of non-compliance?

Who will Benefit:

  • Internal Auditors
  • Regulators,
  • Legal Department Personnel
  • Compliance Officers
  • Money Laundering Prevention Officers
  • Compliance Consultants
  • Risk Managers

Topic Background:

As per the FATF’s revised 40 recommendations on anti-money laundering and combating the financing of terrorism, it recommends the adoption of a risk based approach which allows financial institutions and other designated sectors to apply their resources more effectively by focusing on higher risk areas while having more flexibility for simplified measures to be applied in low risk areas.

Course Outline:

Day One (8:30 AM – 5:30 PM) Day Two (8:30 AM – 5:00 PM)

Registration Process: 8:30 AM – 9:00 AM

Session Start Time: 9:00 AM

Welcome and Introductions (30 Minutes)

  1. Understanding the Basics (1 Hour)
    1. Risk Based Approach 101
      1. Risk based approach definition
      2. Enterprise wide compliance program definition
  1. Risk Assessment (3 Hours)
    1. Identify and classify various risk categories within your organization
      1. Country Risk/Cross border Risk
        1. Sanctions/Embargoes – The Office of Foreign Assets Controls (OFAC)
        2. Countries with inadequate AML/CFT laws and regulations
        3. Countries having a significant level of corruption/other criminal activity
        4. Guidance on assessing country risk
          1. International Narcotics Control Strategy Report;
          2. CIA FACT Book;
          3. Organization for Economic Cooperation and Development (OECD) country list
          4. Financial Action Task Force (FATF);
          5. Transparency International reports.
      2. Customer Risk
      3. Business and Entity Risk
      4. Product/Service Risk
      5. Transactional Risk
    2. Gap Analysis – holistic approach
      1. International influences
      2. Regulatory guidance and expectations
      3. Frequency of assessment
        1. Event driven
        2. Set time period
      4. Documentation of assessment
      5. Resource allocation
  2. Policies and Procedures (3 hours)
    1. Board of Directors/Senior Managements role
      1. BSA/AML approved policies and procedures
      2. Compliance Culture – “tone at the top”
    2. Internal Controls
      1. Regulatory standards – e.g. BSA/OFAC/US Patriot Act
      2. Customer Identification:
        1. Know Your Customer
        2. Simplified Procedures – low risk clients;
        3. Enhanced due diligence – Higher risk clients;
      3. Specific High Risk considerations
        1. PEP’s – Domestic and Foreign PEP’s
        2. Cash intensive businesses
        3. Correspondent Banking
        4. Money Service Businesses
        5. Private Banking
        6. Private Investment Companies – Ultimate Beneficial Owner/Bearer Shares
      4. Recordkeeping
      5. Review process
        1. New laws/regulations
        2. New products and services
        3. Set time period
      6. Case Study – Ineffective Policies and Procedures - Money Laundering/CFT Vulnerabilities

    Welcome (15 Minutes)

    1. Transaction Monitoring (1 Hour)
      1. Rule based vs. behavior based
      2. Large Currency Transactions
      3. Tailor made solution
      4. Alert management
      5. Adequate staffing – experience, critical analysis
      6. AML Metrics – analysis of alerts
      7. Review of process
      8. Case Studies: transaction monitoring enforcement actions
        1. What went wrong
        2. Prevention and detection techniques/guidance
    2. Suspicious Activity Reporting (SAR) process (1 hour)
      1. To file or not to file an SAR
        1. Investigative Process
        2. Detailed documentation of decision
        3. Quality of SAR narrative
        4. Timeliness of filing
    3. Training Plan (1 hour)
      1. Training assessment
      2. Devising an annual training plan/Documenting trainings
      3. Training adequacy assessment
    4. Independent testing of processes ( 2 hours)
      1. Policies and Processes adherence
      2. Customer Identification verification/Due Diligence reviews
      3. Transaction Monitoring – Independent testing
        1. Model design validation
        2. Data integrity checks from source systems
        3. Processes: workflows review
        4. System: automated or manual systems
        5. Adequately trained staff
      4. Documentation/tracking of remediation - deficiencies
      5. Reporting to the Board of Directors/Senior Management
      6. Continuous testing
    5. Limitations of the Risk Based approach (30 minutes)
      1. Pros and Cons of the risk based approach
    6. The Risk Based Approach Toolkit ( 1 Hour)
      1. Risk Based Approach guidance
      2. Risk assessment guidance
      3. Keys to an effective Enterprise wide Compliance Program
      4. References and Links
    7. Conclusion/Wrap up session (30 minutes)

Meet Your Instructor

Andrea Saunders
Founder, Chief Compliance Consultant, Risk and Compliance Consultancy Services Ltd

Andrea Saunders has been branded as one of the leading Compliance Professionals within the Financial Services Industry. Ms. Saunders has set herself apart as a results oriented professional who knows how to accomplish any task regardless of how insurmountable the task. She has worked in Executive roles in Legal & Compliance demonstrating proven leadership and teamwork skills. Under her direction, companies have achieved unprecedented success within their compliance programs which have been evident in numerous satisfactory internal, external and regulatory audit results. She has over fifteen years of experience within both the Legal and Compliance fields.

She was employed at one of the leading law firms in The Bahamas, namely, Higgs & Johnson as an Associate Attorney. She was also the Head of Legal and Compliance for BSI Bank (formerly Banca del Gottardo). After 3 successful years within BSI Bank, she became the Head of Compliance for UBS (Bahamas) Ltd., UBS Trustees (Bahamas) Ltd., and UBS Trustees (Cayman) Ltd. During such time, she was responsible for all compliance related matters for all three entities.

She remained with UBS for 5 years before founding Risk and Compliance Consultancy Services Ltd which is a premier consultancy company with a team of qualified professionals and experts who have over 35 years combined experience within the legal, compliance, accounting and risk management fields.

She is a fellow member of the International Compliance Association, a Certified Anti-Money Laundering Specialist, a CAMS (Audit) Inaugural Class member, a Fellow Member of the American Academy of Financial Management (AAFM), a Chartered Certified Risk Analyst (CRA) and a Certified Anti-Money Laundering Consultant (CAMC). She has also served as an Executive Committee member of The Bahamas Association of Compliance Officer ("BACO") for the past 6 years where she has assisted with the development of Compliance on a national level. She recently served as the Education Chairperson of BACO with responsibility for organizing training initiatives for the association members.

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