Kevin Edwards taught the All About Suspicious Activity Monitoring & Reporting. Here he talks about the “Why”. Get it on-demand.
Types of Suspicious Activity & Reporting Triggers
Decision Making & Timing Requirements
Form Completion Best Practices & Quality Control
Confidentiality & Consequences of Non-Compliance
Designed for BSA/AML personnel, management, compliance officers, auditors and other risk management or operations personnel.
With that, let’s get started. We’ve got a lot of ground to cover, but I always like to start off with why is this so important? It’s always worth starting off with a why. Now, since this is a BSA specific webinar, I really don’t need to explain to you from a regulatory perspective why this is so important because everybody knows that suspicious activity reporting element of your BSA AML program, it’s really the cornerstone. And a lot of how your system is going to be judged from a regulatory perspective is based on how well this suspicious activity reporting is working and how well you’re documenting it, because it’s really a vital element of the program.
Even as we have seen some slight deregulation in the banking industry, you’ve noticed that they’re actually ramping up the expectations from a BSA perspective. So it’s not slowing down even in the deregulatory swing of the pendulum. The other thing that you might want to write down on the front of your page is just remember that, for the first time ever, there was personal liability assigned to a compliance officer for failings in a BSA program. So if you don’t know what I’m talking about, look at the US Bank regulatory enforcement action, because it’s pretty interesting. FinCEN, for the first time, cited someone individually and had a pretty hefty monetary fine levied against somebody because they really had some major failings in their BSA AML program. Things like inadequate SAR monitoring and failure to report SARs. So it really relates to some of the things we’re going to talk about today.
Now, that’s the in-house regulatory perspective, but then also there’s the criminal justice element to the BSA program. There are a lot of bad actors out there. There’s a lot of crime that banks are in a special position to monitor for. So, in the back of your head, as we’re going through this, keep in mind, this is a vital element into fighting things like human trafficking, terrorist financing, money laundering that’s tied to organized criminal activity. And the other thing to keep in mind is that we just got in exam manual update that provided us a little more detail. And one of the areas that it enhanced was the concept of the MLTF and other illicit financing. There’s a new acronym out there that we’re going to get into detail later today, but that acronym should work its way into your monitoring program. So we’ll talk about it a little more when we get there.
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