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BSA/AML/OFAC Annual Training - Overview

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by

Jason Specht

on 21 November 2013

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Transcript of BSA/AML/OFAC Annual Training - Overview

h i s t o r y
m o n e y
LAUNDERING
controls to ensure everything works
USA PATRIOT Act
United and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act
Penalties
transaction amount + up to $500K
highlights government screening of criminal/terrorist lists
lists any exceptions to identifying procedures
its a board approved policy with specific procedures
up to 3650 days in jail
requires identifying information to be retained for 5 years
purpose; set standards for verify identity of new members, non members and businesses
member identification program
bank secrecy act
...assist law enforcement officials in the investigation of money laundering, tax evasion, and other criminal activity.
board approved policy and specific procedures to address compliance
risk assessment required to understand potential impacts
designated individual responsible for compliance with the risk assessment, policy and procedures
report required for transactions of more than $10K cash in 24 hrs
c u r r e n c y t r a n s a c t i o n r e p o r t
e x e m p t i o n s
not confidential, and
certain businesses may qualify for CTR exemption; there eligibility requirements, forms and annual review process associated with exemption
o u r i n t e r n a l s o l u t i o n
currency transaction F O R M
identify transactor and report all associated parties
k i t i n g
what is
s u s p i c i o u s

F R A U D
identity theft
t r u c t u r i n g
a l t e r e d
transaction b e h a v i o r
nervous
MBEZZELMENT
f o r g
e
r y

t h r e a t s
O D D
van
alism
BRANCH
S
OCUMENTS
x t e r i o r
BSA. USA PATRIOT Act. OFAC. Annual Training
osama bin laden
illustration for TIME
by zach trenholm
placement.
layering.
integration.
money laundering
suspicious activity report
S A R
see something. say something.
monetary
i n s t r u m e n t s
i n t e r n a l s o l u t i o n s
m o n e t a r y
instrument report
i n t e r n a l s o l u t i o n s
suspicious incident report
the

S I R
jason k specht
CUCE, BSACS
vp compliance
member one fcu
FinCEN
OFAC
financial crimes enforcement network
office of foreign assets control
originator.
beneficiary.
penalties
it controls economic & trade sanctions
SDN list
transaction and account screening
positive match = freeze assets + notify OFAC
USA PATRIOT Act - section 314
update lists every two weeks
for positive matches = notify finCEN
sample entry
ABD AL HAFIZ, Abd Al Wahab (a.k.a.
FERDJANI, Mouloud; a.k.a. "MOURAD"; a.k.a.
"RABAH DI ROMA"), Via Lungotevere Dante,
Rome, Italy; DOB 7 Sep 1967; POB Algiers,
Algeria (individual)
MANJARREZ, CARLOS
01/18/1958
N4062178
545061495
6416 FRIARS ROAD UNIT 304 SAN DIEGO CA 92108
888 PROSPECT STREET SUITE 100 LA JOLLA CA 92037
sample entry
retention
5
years
d u e d i l i g e n c e
m e m b e r
b u s i n e s s
what do we know and what we should expect
+
collect information @ account opening
and/or
ongoing
detailed information that includes :
transaction activity
&
explanations for changes in transaction behavior
location
purpose
i n t e r n a l s o l u t i o n s
account activity review
FORM
Bank Secrecy Act (1970)
The Money Laundering Control Act (1986)
Annunzio–Wylie Anti-Money Laundering Act (1992)
1980
1990
1970
2000
Money Laundering Suppression Act (1994)
Money Laundering and Financial Crimes Strategy Act (1998)
USA PATRIOT Act (2001)
2010
big penalties + up to 10,950 days in prison +
new job
Verafin does this for us
we use Verafin for this, too!
includes acceptable identifying documents that can used
recordkeeping and reporting
currency transaction report
transaction monitoring
federal crime
Anti-Drug Abuse Act (1988)
monetary instruments
broadened reporting
suspicious activity reports
wire transfers
training
procedures
money service businesses (MSB)
examiners
geographic areas
penalties
information sharing
due diligence
sanctions
identification procedures
Intelligence Reform and Terrorism Prevention Act (2004)
cross-border transfers
currency transaction reports (FinCEN)
-

129
2011
suspicious incident reports (internal)
-

120
2011
more details in job specific training
make a mistake?
$$$ + jail +
unemployed
no exemptions at member one currently
currency transaction reports (FinCEN)
-

191
2012
S
TRUCTURING
changing the cash amount of a withdrawal or deposit to avoid currency transaction reports.
more details in job specific training
suspicious incident reports (internal)
-

104
2012
more details in job specific training
314(a)
information request
(specially designated nationals)
can't comply?
everything you've learned about today is kept for
more details in job specific training
more details in job specific training
any wire over $3,000...
...we record it
more details in job specific training
more details in job specific training
- signed within 45 days following 9/11
- purpose; to obstruct terrorist funding
AND
annual/periodic training
annual independent audits
when?
who?
the

CTF
is

available upon request
step 1
introducing cash into the financial system
step 2
carrying out complex financial transactions to camouflage the illegal source
step 3
acquiring wealth generated from the transactions of the illicit funds
when?
what?
anything you think is odd.
highly confidential report
don't tell the suspect
reports can be filed on known or unknown individuals
including employees and volunteers
30 day deadline to file
after the incident
thresholds for certain suspects
the compliance department manages this
anything discussed in
the previous three slides are suspicious
details.
official checks and money orders
what?
required to record transactor information associated the cash purchase of a monetary instrument
what's the big deal?
any threshold?
cash purchases between $3K and $10K
occupation/industry
Member Identification Program
Full transcript