aml training and awareness for boards and senior managementcontent.aba.com/briefings/3015115.pdf ·...

ABA BRIEFING | PARTICIPANT’S GUIDE

AML Training and Awareness

for Boards and Senior Management

Wednesday, November 9, 2016 Eastern Time

2:00 p.m.–3:30 p.m. Central Time

1:00 p.m.–2:30 p.m. Mountain Time

12:00 p.m.–1:30p.m. Pacific Time

11:00 a.m.–12:30 p.m.

American Bankers Association AML Training and Awareness for Boards and Senior Management Wednesday, November 9, 2016 ▪ 2:00 – 3:30 p.m. ET

DISCLAIMER This Briefing will be recorded with permission and is furnished for informational use only. Neither the speakers, contributors nor ABA is engaged in rendering legal nor other expert professional services, for which outside competent professionals should be sought. All statements and opinions contained herein are the sole opinion of the speakers and subject to change without notice. Receipt of this information constitutes your acceptance of these terms and conditions.

COPYRIGHT NOTICE – USE OF ACCESS CREDENTIALS © 2016 by American Bankers Association. All rights reserved. Each registration entitles one registrant a single connection to the Briefing by Internet and/or telephone from one room where an unlimited number of participants can be present. Providing access credentials to another for their use, using access credentials more than once, or any simultaneous or delayed transmission, broadcast, re-transmission or re-broadcast of this event to additional sites/rooms by any means (including but not limited to the use of telephone conference services or a conference bridge, whether external or owned by the registrant) or recording is a violation of U.S. copyright law and is strictly prohibited.

Please call 1-800-BANKERS if you have any questions about this resource or ABA membership.


II

Table of Contents

TABLE OF CONTENTS ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II

SPEAKER & ABA STAFF LISTING ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III

SPEAKER BIOGRAPHY ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV

PROGRAM OUTLINE ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V

CONTINUING EDUCATION CREDITS INFORMATION ... . . . . . . . . . . . . . . . . . . . . . . . . VI

CPA SIGN-IN/SIGN-OUT SHEET ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VII

INSTRUCTIONS FOR RECEIVING CERTIFICATES OF ATTENDANCE .. VIII

PROGRAM INFORMATION ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ENCLOSED

PLEASE READ ALL ENCLOSED MATERIAL PRIOR TO BRIEFING. THANK YOU.

The Evaluation Survey Questionnaire is available online.

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Thank you for your feedback.

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Speaker and ABA Staff Listing

Speaker ALAN ABEL, CPA/CFF, CFE Global AML Practice Director Crowe Horwath LLP 401 East Las Olas Boulevard Suite 1100 Fort Lauderdale, FL 33301 (202) 257-9178 Fax: 954 202 8639 [email protected]

ABA Briefing Staff CARI HEARN Senior Manager (202) 663-5393 [email protected] LINDA M. SHEPARD Senior Manager (202) 663-5499 [email protected]

American Bankers Association 1120 Connecticut Avenue, NW Washington, DC 20036 www.aba.com

mailto:[email protected]



http://www.aba.com/


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Speaker Biography

ALAN ABEL Alan has worked with the boards and executives of more than one hundred global and regional bank and non-bank financial institutions, to help them develop and strengthen their governance, business processes and controls, risk assessment and risk management connected with money laundering, fraud, corruption, related financial crime, and economic sanctions and interdiction. Alan has more than twenty years of experience managing large, complex domestic and international projects and financial management operations. He is responsible for Quality Assurance for Crowe Horwath Financial Crime engagements. He is formerly Managing Director and Global AML Practice Leader for a Big Four Firm where he won the annual Financial Services Award for outstanding client service. Alan has testified as a private industry expert at the U.S. Senate Hearing on "The Threat to U.S. Trade and Finance from Drug Trafficking and International Organized Crime." Alan has written numerous articles and is quoted frequently by the press, has made live appearances on CNN “SquawkBox” and CNBC “Maverick of the Morning,” and speaks frequently in professional venues.


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PROGRAM OUTLINE

TIMES SESSION AND SPEAKERS 1:45 – 2:00 p.m. ET

Pre-Seminar Countdown

2:00 – 2:02 p.m.

Welcome and Introduction Speaker Introductions 1Source International

2:02 – 3-20 p.m.

What is truly Important for Boards to Know and Why Regulators Expectations What questions should they be asking What information senior management should be providing What is Too Much Information (TMI)? Alan Abel, Crowe Horwath LLP

3:20– 3:30 p.m.

Wrap-up and Questions & Answers


VI

Continuing Education Credits Information

The Institute of Certified Bankers™ (ICB) is dedicated to promoting the highest standards of performance and ethics within the financial services industry.

The ABA Briefing, “AML Training and Awareness for Boards and Senior Management”

has been approved for 2.0 continuing education credits towards the CAFP and CRCM designations.

To claim these continuing education credits, ICB members should visit their ICB Certification Manager on the ABA’s Learning Management System (LMS) at https://aba.csod.com/client/aba/default.aspx. You will need your member ID and password to access your personal information. If you have difficulty accessing the Website and/or do not recall your member ID and password, please contact ICB at [email protected] or 202-663-5092.

American Bankers Association is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org.

1.5 CPE credit hours (Business Management & Organization) will be

awarded for attending this group-live Briefing.

Participants eligible to receive CPE credits must sign in and out of the group-live Briefing on the CPA Required Sign-in/Sign-out Sheet included in these handout materials. A CPA/CPE Certificate of

Completion Request Form also must be completed online. See enclosed instructions.

Continuing Legal Education Credits This ABA Briefing is not pre-approved for continuing legal education (CLE) credits. However, it may be possible to work with your state bar to obtain these credits. Many states will approve telephone/ audio programs for CLE credits; some states require proof of attendance and some require application fees. Please contact your state bar for specific requirements and submission instructions.

https://aba.csod.com/client/aba/default.aspx


http://www.learningmarket.org/


VII

CPA Required Sign-in/Sign-out Sheet

CPAs may receive up to 1.5 hours of Continuing Professional Education (CPE) credit for participating in this group-live Briefing.

INSTRUCTIONS: 1. Each participating CPA must sign-in when he/she enters the room and sign-out when he/she

leaves the room. 2. Name and signature must be legible for validation of attendance purposes as required by NASBA. 3. Unscheduled breaks must be noted in the space provided. 4. Each participating CPA must complete an online CPA/CPE Certificate of Completion Request

Form (instructions found on next page). 5. Individuals who do not complete both forms and submit them to ABA will not receive their

Certificate of Completion.

This CPE Sign In/Out Sheet must be uploaded with the CPE / CPA Request for

Certificate of Completion form in order for the CPA to receive his/her Certificate of Completion.

FULL NAME

(PLEASE PRINT LEGIBLY) SIGNATURE TIME

IN TIME OUT

UNSCHEDULED BREAKS

American Bankers Association is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org.

Please note: CPE credits are ONLY awarded to those who have listened to the live broadcast of this Briefing.



VIII

Instructions for Receiving Certificates of Completion

CPA/CPE Certificate of Completion

Submission of a sign-in/sign-out sheet AND request for a Certificate of Completion are required for the validation process to be completed.

NASBA requires ABA to validate your attendance in order for

you to receive your Certificate of Completion.

1. COMPLETE a CPA / CPE Certificate of Completion Request Form online at: https://aba.desk.com/customer/portal/emails/new?t=546545

2. SCAN AND UPLOAD the completed CPE / CPA Required Sign-in/Sign-out Sheet (enclosed) and attach it to the REQUEST for CPE/CPA Certificate of Completion form found in Step 1.

3. SUBMIT completed Request Form and Sign-in/out Sheet

4. VALIDATION ABA will VALIDATE your attendance within 10 business days from receipt of Request Form and Sign-in/out Sheet

5. A personalized certificate of completion will be emailed to you once your attendance is validated

6. QUESTIONS about your certificate of completion? Contact us at [email protected].

General / Participant’s Certificate of Completion 1. REQUEST a General Certificate of Completion at:

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2. A personalized certificate of completion will be emailed to you within 10 business days of your request.

3. QUESTIONS about your certificate of completion? Contact us at [email protected].





11/7/2016

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aba.com1-800-BANKERS

AML Training and Awareness for Boards and Senior Management

American Bankers Association Briefing/WebinarWednesday, November 9, 20162:00 – 3:30 p.m. ET

aba.com 1-800-BANKERS

Disclaimer

This Briefing will be recorded with permission and isfurnished for informational use only. Neither the speakers,contributors nor ABA is engaged in rendering legal norother expert professional services, for which outsidecompetent professionals should be sought.

All statements and opinions contained herein are the soleopinion of the speakers and subject to change withoutnotice. Receipt of this information constitutes youracceptance of these terms and conditions.

11/7/2016

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Presenter

• Alan Abel, Global AML Practice Leader, Crowe Horwath, LLP


Agenda

Why me? Training and awareness AML 101 AML 401 Understanding risk Understanding control Why history is important Know Your Customer -- the Dance of the Seven Veils.

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Why Me?

• It’s required• Your Supervisors expect you to make the compelling case that

you govern yourselves well in all respects – AML is no exception• As a Board Director you need to understand your organization’s

risk and control environment • You need to set risk appetite• You need to approve the BSA officer and acknowledge and

accept the BSA/AML program• You need to understand the program information that

management will report to you• You might get a call• You very likely have something to contribute.


Training and Awareness

• Training• Awareness

– What’s the organization’s vulnerability / risk?– What safeguards / defenses / controls are in place to manage the risk? What are our lines of

defense?– What’s the BSA/AML/OFAC history of the organization?

• Program• Compliance• Examination • Audit

– History and context – why are things the way they are today?– What is management’s strategic and operational planning process? – How do we compare to others?– What has employee turnover been like?– Predictions?

• Awareness is not passive – it also embraces continuing conversations that you need to have.

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Training and Awareness

• Management’s challenge -- keeping information “big picture”, salient, interesting

• Feedback to management– Ask why do I need to know this?– Here’s what I want to know and understand– Here’s what I want to stay informed about.

• Board and Senior Management together– Need to be on same page– Need to be part of the same conversation– AML / financial crimes / sanctions– Surprises are not usually nice ones.


AML 101

• Everybody • Most “covered” organizations rely on Computer-Based

Training (CBT) these days for basic training. • Regulators expect (and require) that all employees and

service providers of consequence receive at least AML 101. So should the Board.

• New versus seasoned board members• Basic requirements for 101 full board training

– Understanding and accepting a refreshed program– Program components– Appointing the BSA Officer (rule)– Training (rule)– Independent Testing (rule).

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AML 101 . . .

• What is a “sound practice” written program?1. Board-approved “policy framework”2. Enterprise-wide guidance and standard3. Implementing and operating policies and procedures.


Three levels of documentation . . .

1. What is a Board-approved “policy framework”?– Just what it sounds like -- what are our policies? – Fewer than 100 pages, uncluttered – Also define the senior actors (positions, units, and

committees of consequence) and their roles– No names (they will change tomorrow).

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2. What are “guidance and standards”?

– Also < 100 pages – Global and enterprise-

wide– Soft law versus hard law.

• Important areas:– Code of Conduct, Tone-

at-the-top, ethics– The KYCs– Training– Diversity and inclusion– Social responsibility– Social media– Protecting people, assets,

reputation– Conflicts of interest– Reporting violations.



3. What are implementing and operating policies and procedures?• Who, what, why, when, where, how• Bookshelves• Business units and support areas of consequence• Need to be orchestrated by compliance in a well-organized

manner.• Well-maintained. • Examiners and auditors test them. Depend on it.

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(More) sound practice documentation

– Meeting agendas– Well-written, reviewed, and approved minutes

• You should receive and review them before the meeting and before accepting them.

– Action items, results, follow-up– Clear and meaningful management and Board reports– Clear written communications that spell “living and

breathing”. This is evidence that your program is working as intended

– Less More is more. • Copious minutes, emails, memoranda, frequent web-site

updates demonstrate that the Program is active and energized and that there are many active players.


AML 401 . . .

• AML Training is also risk-based. It is a sound practice that higher risk and specialized areas receive more advanced, specialized, and tailored training.

• Where committee oversight recommends • Committee structure and charters

– Audit committee– Compliance committee– Risk committee– Ad hoc committees.

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Understanding Risk

• Regulatory risk frameworks differ– Supervisor to supervisor– Country to country– Basel seeks to set a global model, standards.

• Common denominator– All frameworks identify and define a set of quantitative

and qualitative risks.


Understanding Risk . . .

• Quantitative Risks (examples)– Interest rate– Liquidity– Exchange rate– Credit.

• Not really about AML, financial crime, sanctions

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• Qualitative Risks– Compliance– Reputational– Operational – Strategic

• Absolutely about AML, financial crime, sanctions . . .



• FFIEC BSA/AML Exam Manual– Customers– Products and Services– Geographies… (everyone knows this)

• But AML risk assessment processes tend to focus on these and may not get their arms around reputational and strategic risk in the business units and support areas.

11/7/2016

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• You need to set risk appetite for the organization. So management needs to provide you with a comprehensive AML risk assessment at least annually (with an executive summary).

• Risk assessment process should be more of a going concern than a one-shot sprint.

• Management’s risk assessment challenges that you want to get a comfort level about:

– What are the risk assessment units?– How does management get to “apples and apples” unit-wise, trend-wise?– Why is management comfortable with the process? Data integrity? What is the technology

of the risk assessment process? Is it a spreadsheet factory?– What are the opportunities for improvement next go-round? Are you getting a sense of

continuous improvement? – What have examiners and auditors observed about your risk assessment process? What

recommendations have been made? Have they been acted on? – How does management enforce salient, substantive response? – What are the controls over responses, completeness, certifications, supervisory or

compliance review, analysis? Are results properly reviewed and discussed for rationality, meaningfulness?



• To keep your head above water, keep asking management these very big questions:– What bad things have happened recently at organizations like

ours?– What bad things do you worry about happening here?– What is the likelihood of those bad things happening here? – If one of those bad things happened, how bad would it be?

What would the consequences be?– Do we have a “plan in a can” ready to deploy should a bad

thing happen here?– And as Board Directors, what would our role be? How should

we prepared to help?

11/7/2016

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Understanding Control . . .


Universal control framework

COSO* Framework for Enterprise Risk Management

• Has become a global standard • Not just about financial reporting Model clearly highlights four

control objectives universal to organizations, add: Operational Compliance Strategic.

*COSO Enterprise Risk Management – Integrated Framework Executive Summary September 2004

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COSO . . .

• At this point, many boards are, and most audit committees are reasonably well-versed with the COSO framework of internal control.

– More maturity with respect to using the model in connection with the financial reporting control objective

– Basis of an important auditing standard (understanding the control environment)

– Sarbanes – Oxley.• COSO ERM model works very well for AML / financial crime /

sanctions vis-à-vis the other three control objectives• Keep in mind that money laundering and financial reporting are

vectors askew– Money laundering doesn’t affect financial statements, results of

operations.– Material fraud can and quite likely will.

• The best – worst customer principle • Important conversations especially for the audit, compliance,

and risk committees.


COSO . . .

The COSO ERM model is comprehensive to activities at all levels of the organization:

• Enterprise-level• Business unit or subsidiary• Business unit processes • Support area processes.

11/7/2016

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History and context

• Most program training is about “what” and not about the “why”. Awareness begs the “why”.

• BSA / AML history is very interesting, compelling like a best-seller action novel.

• Important to understand why things are the way they are today, and to get a sense of where we are headed.

• Meaningful Board engagement requires meaningful comprehension and interest.


Important and interesting to know . . .

• How the BSA of 1970 was a Congressional reaction to tax evasion and not really much about money laundering on opening night.

• How the CTR requirement went virtually ignored and unenforced until the Federal Reserve made an example of the Bank of Boston in 1986; how that resulted in a flood of CTRs; how that has led to today’s continuing conversation regarding usefulness to law enforcement and the risk to financial institutions.

• How the BSA has been amended by Congress more than 100 times and why (you don’t need to know them all).

• The vast power that Congress has delegated to the Treasury Secretary, most of which has gone unexercised over the past 46 years.

• That not a few of those amendments have been to force the Treasury Secretary to exercise that power, and not necessarily with the best wishes of the incumbent administration.

11/7/2016

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• How the scope of the “BSA covered financial institution” expanded from conventional deposit-taking and lending institutions, products and activities to all manner of bank and non-bank financial institutions, and the wild card.

• How the BSA expanded from Currency Transaction Reporting to Suspicious Activity Reporting, the impact of that to covered financial institutions, and lessons learned, especially by other countries with orchestra seats.

• How the playing field got more level and the impact.



• How BCCI made money laundering and financial crime a “global phenomenon”, and made it the agenda de jour of a G-7 annual economic summit

• How that resulted in the Financial Action Task Force, the “global AML watchdog” and landed it in the OECD.

• How the United Nations and the Bretton Woods institutions got involved and their impact

• How the U.S. AML model and regime differ from most others and why, and the impact

• How the Congressional privacy rebellion at the turn of the century impacted Know Your Customer and how September 11 and the USA PATRIOT Act put an end to that almost overnight.

11/7/2016

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• How the BSA implementing regulators have responded, the impact of their response on those they supervise today, how that has affected the institution you govern, and why your AML/CTF and sanctions compliance programs are almost always the most pervasive and expensive programs in covered financial institutions today.

• The extraordinary regulatory and law enforcement challenges facing the U.S. AML regime today, and the armies of people who play a roletoday.

Case history is vast and full of “lessons learned”. It’s invaluable to hear and discuss cases and their consequences at every opportunity.


Know Your Customer and the Dance of the Seven Veils

• Everyone has a KYC et al. program, and tries to sustain and enhance their KYC programs and KYC cultures.

• It’s important to keep in mind that AML / financial crime is only one of seven reasons that KYC is important . . .

11/7/2016

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The Seven Veils of KYC . . .

• Fundamentally, KYC is good business.• ML, fraud, related financial crime, terror financing, CIP,

beneficial owner, controlling interest• Global sanctions and lists (including suspected

terrorists)• Corruption• Suitability, sales practices, consumer protection• Privacy preferences and protections• Tax compliance, “qualified intermediaries”, FATCA.


Recent Article in The Journal of Accountancy

“Money laundering: Combating a global threatThe vigilance of CPAs plays an important part in an international effort to deter financial crime.”

(http://www.journalofaccountancy.com/issues/2016/sep/money-laundering-financial-crime.html)•

By Alan S. Abel, CPA/CFF, and Ian A. MacKay, CPA, CGMASeptember 1, 2016

11/7/2016

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Questions and Answers

If you are participating on the Web:Enter your Question in the Box Below

and Press ENTER / SUBMIT.

If you are participating by Phone:Email your Question to: [email protected]

ABA BRIEFING

Managing 2017 Compliance Priorities Presented by: ABA Center for Regulatory Compliance Wednesday, December 14, 2016 ▪ 2:00–4:00 p.m. ET*

Members of the American Bankers Association’s Financial Institutions Policy and Regulatory Affairs (FIPRA) Group will provide insights on how recent regulatory developments will impact how you manage your compliance risk and examination challenges in 2017 and beyond. Our panel of ABA experts will give you pointers about what you might expect from regulatory agencies and Congress as only ABA can. Learn what to do to keep pace with the changing regulatory landscape. This program is not a regulation training session, but is designed to give you an update that will help you identify compliance risks to support your assessment process and stay ahead of the evolving compliance oversight curve. Check your “to do list” against our suggestions about what to prepare for in 2017. The Briefing will focus on: BSA/AML/OFAC Still Matter—CDD and sanctions HMDA—preparing for the new disclosure regime ADA—requirements for accessible websites and mobile Apps Mortgage Origination—making sense of TRID and RESPA section 8 Mortgage Servicing—implementation of the latest amendments Fair Lending Enforcement and CRA Performance—lessons learned from recent cases Military Lending Act implementation The future of small dollar lending and overdraft Debt collection—new rules on the horizon Flood Insurance—prospects for NFIP reauthorization priorities Prepaid final rule implementation TCPA—prospects for reform? Vendor management on steroids—implications of the FDIC proposed third-party

lending guidance Diversity Self-Assessments—What the regulators expect ABA’s FIPRA Group Panelists: Virginia O’Neill, SVP Nessa Feddis, SVP and

Deputy Chief Counsel Rob Alba, SVP and Sr. Regulatory

Counsel Robert Rowe, VP and Associate

Chief Counsel Krista Shonk, VP and

Sr. Regulatory Counsel Jonathan Thessin, Sr. Counsel Anjali Phillips, Sr. Counsel Rick Freer, Sr. Director Toni Cannady, Sr. Research

Assistant, Compliance

Who Should Attend? Compliance Officers Compliance Managers Bank Counsel Risk Managers and Auditors Senior Bank Managers CRCMs, CPAs

REGISTRATION FEES ABA/ICB/Service Member $265 per registration per briefing Non-Member $395 per registration per briefing

Live registration provides a connection for one room where unlimited listeners can be present, and streaming online recording access FREE for 7 days. Any transmission, retransmission or publishing of this briefing is strictly prohibited.

2 EASY WAYS TO REGISTER Online: aba.com/briefings Call: 1-800-BANKERS GET THE CREDIT YOU DESERVE! This briefing is being reviewed for continuing education credits eligibility. American Bankers Association is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org

You are receiving this communication because of your established business relationship with the American Bankers Association. Our objective is to provide you with the most relevant information, opportunities and issues impacting the financial services industry. If you would like to change your communication preferences, unsubscribe or receive additional information please contact 1-800-BANKERS or email your request to [email protected]. Your request will be processed within 30 days of receipt, as required by law.



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OTHER EVENTS TAKING PLACE:

Mutual Community Bank Forum, March 19 – 20

Emerging Leaders Forum, March 20

Women’s Leadership Forum, March 19

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It’s a pivotal year for Washington—and soon a new presidential

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March 20 –22 | Washington, DC

Two new online certificates will provide in-depth training to individuals about the types of criminal behavior commonly used against banks and the applicable U.S. laws and regulations. Courses cover a comprehensive list of anti-money laundering and fraud topics, including:

Program governance and oversight

Customer onboarding, monitoring, detecting, responding

Regulatory reporting requirements.

Taken together, the two financial crimes online training programs will provide the eligibility requirements for certain candidates preparing for the Certified AML & Fraud Professional (CAFP) exam. They also provide more experienced candidates an opportunity to refresh their knowledge in preparation for the exam.

All courses are accessible anytime, anyplace on desktops, laptops and most mobile devices!

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Online Training for AML and Fraud Professionals

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