BSA/AML High Risk. What’s the Issue?

Why Should You Attend:

An effective BSA/AML compliance program controls risks associated with the institution’s products, services, customers, entities, and geographic locations; therefore, an effective risk assessment should be an ongoing process, not a one-time exercise. Monitoring your risks includes monitoring your transactions, especially your high-risk transactions.

Per the FFIEC Manual: The development of the BSA/AML risk assessment generally involves two steps: first, identify the specific risk categories (i.e., products, services, customers, entities, transactions, and geographic locations) unique to the institution: and second, conduct a more detailed analysis of the data identified to better assess the risk within these categories. Several examples of a system of internal controls will help you document your monitoring program.

The management of compliance risk requires a thorough evaluation of the customer base. Determining the risk rating of a customer – especially those seen as High Risk – plays an important role in the construction of a complete and accurate BSA/AML Risk Assessment. The determination of high-risk Customers may involve a wide array of variables, carefully rated and scored, or a single variable that overrides all others. The factors to calculate high risk – or any risk – must drive an on-boarding system – computer-based or manual. How many high-risk customers must an institution have before the meaning of high risk becomes meaningless? The USA Patriot Act has laid out the requirements for Customer Due Diligence and Enhanced Due Diligence for high-risk customers. The recently implemented FinCEN Customer Due Diligence Rule which formalized the concept of beneficial ownership, provides guidance for the management of high-risk customers. This webinar will examine the regulatory background behind the determination of high risk, weighting and rate factors leading to high-risk scoring, and asking when a high-risk customer is too hot to handle, what is the risk appetite of the institution.

Learning Objectives:

• High Risk Customers and the BSA/AML Risk Assessment
• What makes a Customer High Risk – Institutional Risk Appetite
• Evaluating and Validating Rating Factors
• Enhanced Due Diligence Considerations
• Can an Institution have too Many or too Few High-Risk Customers
• Sample risk assessment for products and services.
• Systems of internal controls.
• Managing Non-Resident Aliens.
• Documenting and Monitoring a Cash In and Cash Out Report.

Areas Covered in the Webinar:

• Resources.
• Accessing the data: What are the obstacles? Core system, teller system, BSA monitoring program, etc.
• How did the activity occur? In person, telephone, internet, wire, ATM, or ACH.
• Sample risk assessment for products and services.
• Systems of internal controls.
• Managing Non-Resident Aliens.
• Documenting and Monitoring a Cash In and Cash Out Report.
• The Customer Risk Rating Profile
• What is High Risk?
• The On-boarding System
• The BSA/AML Risk Assessment
• Country Risk Ratings

Who Will Benefit:

• BSA/AML Officers
• Compliance Officers
• Chief Compliance Officers
• Sanctions Officers
• AML Analysts
• Chief Risk Officers
• Legal Departments Personnel
• Risk Managers
• CEO/Presidents at Banks
• Broker-Dealers
• Money Services Businesses
• Financial Officers
• Front Line Staff
• Operational Managers

Doug Keipper
Certified Anti-Money Laundering Specialist, Leading Bank

Doug Keipper, is a Certified Anti-Money Laundering Specialist (CAMS) since 2005 and a Bank Secrecy Act Officer for a $1 billion dollar bank.
Doug sold BSA software for eight years and has taught anti-money laundering classes since 2008 throughout the southeast and online.
He has talked with over 500 BSA officers throughout the USA and Caribbean.
He has spent over 20 years in retail banking, wholesale mortgages and financial services.

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