2005 Industry AML Challenges

1
2005 Industry AML Challenges

• John J. Byrne
• Director
• ABA Center for Regulatory Compliance

2
2005 Challenges

• Surviving AML Examinations
• Assessing Risk without Guidance
• SAR Policies and Procedures
• Learning the right things from Enforcement
  Actions
• Staying One Step Ahead

3
SAR Policies and Procedures

• What is an acceptable program?
• Resources--SAR Activity Review/Agency Guidance
• Need to Improve Narrative/Quality of Information
• SAR Volume not an Urban Myth!
• OFAC Hits- Change in Policy
• How to Document SAR Non-filings
• Bottom LineFile or Not?

4
AML Examination Issues

• Are expectations realistic?
• Need for Management Support
• Basic BSA knowledge essential
• Interagency Procedures Should Help
• Available Resources
• Training
• Deficiencies must be corrected!!

5
Lessons Learned from Recent Enforcement Actions

• Risk Assessment not tailored to business
• Training was weak and not Up to Date
• SAR Deficiencies
• CTR Violations
• Reputation Risk and Acquisition
• Fragmented Programs
• Lack of Timely SAR Filings