The Importance of a Risk Based Approach in Implementing and Maintaining an Enterprise Wide Compliance Program

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

2. Risk Assessment (3 Hours)
2. 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
3. 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
3. Policies and Procedures (3 hours)
4. Board of Directors/Senior Managements role
1. BSA/AML approved policies and procedures
2. Compliance Culture – “tone at the top”
5. 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)

4. 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
5. Suspicious Activity Reporting (SAR) process (1 hour)
9. 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
6. Training Plan (1 hour)
10. Training assessment
11. Devising an annual training plan/Documenting trainings
12. Training adequacy assessment
7. Independent testing of processes ( 2 hours)
13. Policies and Processes adherence
14. Customer Identification verification/Due Diligence reviews
15. 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
16. Documentation/tracking of remediation - deficiencies
17. Reporting to the Board of Directors/Senior Management
18. Continuous testing
8. Limitations of the Risk Based approach (30 minutes)
19. Pros and Cons of the risk based approach
9. The Risk Based Approach Toolkit ( 1 Hour)
20. Risk Based Approach guidance
21. Risk assessment guidance
22. Keys to an effective Enterprise wide Compliance Program
23. References and Links
10. Conclusion/Wrap up session (30 minutes)

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.