Banking Fast Fact: BSA/AML Penalties

>$3.2 Billion

In 2012 – Regulatory agencies assessed fines and penalties against a number of institutions that exceeded $3.2 billion; the largest amount in BSA/AML penalties ever imposed over a one year period.

Read “Assessing Inherent BSA/AML Risk at Community Banks,” prepared by Community Banking Connections – a nationwide Federal Reserve System resource for community banks. The article concludes “Understanding an institution’s inherent risk is the first step in developing a strong BSA/AML compliance program, and getting it right has never been more challenging. At the same time, the stakes for noncompliance have increased. Banks with strong BSA/AML compliance programs have made ongoing risk assessment a priority for their institutions, included their BSA compliance officer in new product development discussions, and set the right tone at the top of the organization.”

A Broadleaf Group Banking Consultant can provide guidance with a no-cost assessment of your compliance program.
Call 1-866-837-4103 or fill out the form in the right sidebar to get started.

JOIN THE BSA/AML LINKEDIN GROUP

Click this link http://linkd.in/1w9WKP6 to join the Bank Secrecy Act/ Anti-Money Laundering Roundtable Networking Group on LinkedIn. This group serves as an online gathering place for banking professionals to discuss a variety of topics including:

BSA/Officers General Role and Responsibilities
Employee Training
Current Regulatory Challenges
Enhancing the Risk Assessment
Enhancing Risk-Based Approaches to AML

Action Plan to Maintain a Robust BSA/AML Compliance Program

It is imperative for banks and other financial institutions to develop and implement an action plan to address the heightened regulatory scrutiny and program risks.

Below is an action plan to guide you.

1. Commit Sufficient Resources to Ensure a Strong Compliance Program

An institution must be able to demonstrate to regulators that it has committed the necessary resources – and is willing and able to invest additional resources, as appropriate – to establish and maintain a robust BSA/AML and OFAC compliance program, including investments in technology, staff, training, and monitoring capabilities.

2. Maintain the Strength of Information Technology and Monitoring Processes

In addition to maintaining updated IT software and programs, management and the board of directors of an institution should ensure adequately trained staffing to monitor and supervise these processes and programs.

3. Risk Management

Banking regulators will examine institutions with a focus on ensuring that senior management and the board have taken the time to identify the particular risks posed by an institution’s business model and have designed a BSA/AML and OFAC compliance program that address such risks.

4. Small Institution Risks

Smaller institutions should identify particular lines of business or geographic regions that pose higher risks, and ensure such risks are specifically reflected and addressed in their BSA/AML and OFAC compliance program, policies and procedures.

A Broadleaf Group Banking Consultant can provide guidance with a no-cost assessment of your compliance program. Call 1-866-837-4103 or fill out the form in the right sidebar to get started.

JOIN THE BSA/AML LINKEDIN GROUP

Click this link http://linkd.in/1w9WKP6 to join the Bank Secrecy Act/ Anti-Money Laundering Roundtable Networking Group on LinkedIn. This group serves as an online gathering place for banking professionals to discuss a variety of topics including:

BSA/Officers General Role and Responsibilities
Employee Training
Current Regulatory Challenges
Enhancing the Risk Assessment
Enhancing Risk-Based Approaches to AML

2014 Challenging Trends to Watch

Renewed Regulatory Focus

1. Failure by institutions to commit adequate resources to BSA/AML compliance programs, due to either cost-cutting measures or a failure to keep pace with an institution’s growth.

2. Risks posed by high-risk international financial activities, such as foreign correspondent banking, cross-border funds transfers, remote deposit capture, etc.

3. Failure by institutions to manage and supervise third-party service providers and payment processors.

4. Rapid growth of new technologies, such as mobile banking, prepaid cards, and internet cloud-based payment processors.

A Broadleaf Group Banking Consultant can help you stay on top of these issues and provide an no-cost assessment of your monitoring process. Call 1-866-837-4103 or fill out the form in the right sidebar to get started.

2014 CBA Compliance Conference Highlights

It was great to see everyone at this year’s California Bankers Association Compliance Conference! For those who couldn’t attend, we’ve summarized key topics highlighted in sessions. If there is a particular session you’d like to hear more about, please feel free to contact us. We’d be happy to share what we learned. We can be reached at (866) 837-4103 or Banking@Broadleafgroup.com.

Speakers discussed significant challenges faced by financial institutions in the areas of compliance management, risk management, compliance management strategies and general expectations of banking regulators.

Banking Fraud: Infiltration, Detection, Investigation and Prevention
Eric LaBadie, VP Customer Success, Guardian Analytics
John Marengo, Assistant to the Special Agent in Charge, US Secret Service, Cyber Intelligence Section

This session walked attendees through the lifecycle of a cyber-attack, including how criminals acquire the credentials and information needed to compromise an account or system, how banks can work with the US Secret Service to investigate data breaches, and strategies for detecting and preventing account compromises and data breaches from happening in the first place. Eric LaBadie, of Guardian Analytics, presented the scope of the cybercrime landscape and gave examples that highlight the threats, business risks, and investigative and detection process.

Pitfalls and Strategies in Cloud Computing, Outsourcing and Other Contract Reviews
Jim Curtis, Bank of the West

Jim Curtis discussed the importance of addressing errors that banks make when negotiating vendor contracts, including cloud computing and other IT agreements. Topics covered in this session included data security, intellectual property rights (or the lack thereof) and warranties, along with the almost always misunderstood contracting landmine: indemnity. The panel also discussed strategies for reviewing vendor contracts.

Strategies to Deal with Elder Financial Abuse

Paul Greenwood, Deputy District Attorney, San Diego County
Raymond Lynch, Sr. Company Counsel, Wells Fargo Bank

The speakers focused on dealing with elder financial abuse matters on a daily basis and discussed lessons learned from their respective experiences. They’ve fought elder financial abuse as a criminal prosecutor and in-house bank counsel and shared their experience to provide strategies that financial institution employees can adopt to recognize possible elder financial abuse transactions.

Banking High Risk Customers – Establishing Effective Customer Due Diligence

John Krenitsky, Chief Compliance Officer, Bank of the West

This session explored the characteristics that make certain customers “higher risk” for money laundering and the implications for due diligence on banks who choose to provide services to such customers. This session also covered a review of regulatory guidance/expectation as well as the practical implications on establishing effective customer due diligence.

Surviving the Exam Process from A-Z

Liz Clarkson, Chief Compliance Officer, Umpqua Bank
Radhika Dholakia, Chief Compliance Officer, Sunwest Bank

Speakers discussed how new rules, additional regulatory oversight and focus on consumer protection have increased the number and level of regulatory compliance exams for all banks, whether big or small. This session focused on how to prepare for and survive a compliance exam, best practices and useful tools to help with the bank’s next exam.

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JOIN THE BSA/AML LINKEDIN GROUP

Click this link http://linkd.in/1w9WKP6 to join the Bank Secrecy Act/ Anti-Money Laundering Roundtable Networking Group on LinkedIn. This group serves as an online gathering place for banking professionals to discuss a variety of topics including:

BSA/Officers General Role and Responsibilities
Employee Training
Current Regulatory Challenges
Enhancing the Risk Assessment
Enhancing Risk-Based Approaches to AML

9 Keys for Evaluating BSA/AML Efforts

Take a close look at your bank’s BSA/AML training program to ensure staffing levels are sufficient to perform monitoring and investigation activities. Training can be used proactively as part of an institution’s internal controls.

Here are 9 keys for evaluating your bank’s efforts:

1. New Employees

Provide training prior to hitting the trenches.

2. Wide Coverage

All business lines.

3. Specific Training

Tailored to the employee’s specific duties.

4. Comprehensive Training

Not only on BSA and how to identify suspicious activity, but also include bank’s internal policies, procedures, and systems and/or manual processes. Also, don’t forget covering how to escalate suspicious activity to the appropriate department.

5. Train the Experts Too

BSA officers should receive periodic training that is relevant and incorporates current developments, emerging risks/trends, and changes to the BSA and related regulations.

6. Train Board of Directors and Senior Management

They need training to understand the importance of regulatory requirements, ramifications of non-compliance, as well as risks to the bank.

7. Train for Your Tools

Staff utilizing BSA/AML monitoring systems need to be provided with comprehensive and ongoing training to maintain their expertise.

8. Test During Training

This can be an effective method to determine not only the competence of the staff, but also to judge the effectiveness of the training.

9. Document Training Regime, Training Accomplished and Scores of Any Testing

These scores may become useful to judge the effectiveness of any changes

Once you’ve assessed the state of your BSA/AML efforts, you can develop an action plan to ensure you’re addressing the heightened regulatory scrutiny and program risks. Click here to read a “Action Plan to Maintain a Robust BSA/AML Compliance Program.”

A Broadleaf Group Banking Consultant can provide an no-cost assessment of your monitoring and training process. Call 1-866-837-4103 or fill out the form in the right sidebar to get started.

JOIN THE BSA/AML LINKEDIN GROUP

Click this link http://linkd.in/1w9WKP6 to join the BSA/AML Roundtable Networking Group on LinkedIn. This group serves as an online gathering place for banking professionals to discuss a variety of topics including:

BSA/Officers General Role and Responsibilities
Employee Training
Current Regulatory Challenges
Enhancing the Risk Assessment
Enhancing Risk-Based Approaches to AML

The Broadleaf Group Banking Division Forms BSA/AML Roundtable

The Broadleaf Group Banking Division plans the first quarterly Bank Secrecy Act/Anti-money Laundering (BSA/AML) Roundtable to address compliance challenges and solutions. It will take place on Tuesday, February 3rd, at the Richard Nixon Library in Yorba Linda, CA.

For banking professionals looking for guidance from expert consultants and peers, this is a valuable opportunity to join together to raise issues and collaborate on best practices. BSA/AML expert, Delayne Townzen, will lead this roundtable discussion. Townzen, a former BSA Officer, has over 36 years of banking experience and a deep understanding of the compliance process. She’s reviewed and revised BSA programs, automated AML monitoring and alerts, performed self-assessments based on FFIEC manual, trained personnel and participated in a panel of experts at the California Bankers Association Annual BSA Conference.

“We’ve serviced over 200 banks in the last 25 years and we’re frequently asked about compliance issues,” said Hani Ascha, Director of the Banking Division. “BSA/AML is especially challenging for bankers who try to effectively achieve and document CDD and EDD efforts. In 2015, CDD/EDD efforts will continue to be closely scrutinized by regulators. Banks need to ensure this data is properly documented. We had an overwhelmingly positive response when we gauged interest in a roundtable that brings banking professionals and expert consultants together to address these concerns, so we decided to sponsor this event.”

The first 2.5-hour BSA/AML Roundtable begins at 11:00 AM and will feature time for introductions, followed by an open forum and advice from experienced consultants. It will wrap up with a Q&A session to address specific situations. A complimentary lunch will be provided.

Those unable to attend the event are invited to join the BSA/AML Roundtable Networking Group on LinkedIn. This group serves as an online gathering place for banking professionals to discuss a variety of topics including:

BSA/Officers General Role and Responsibilities
Employee Training
Current Regulatory Challenges
Enhancing the Risk Assessment
Enhancing Risk-Based Approaches to AML
Future events
A Broadleaf Group Banking Consultant can discuss your specific needs at any time. Call 1-866-837-4103 or fill out the form in the right sidebar to get started.

4 Strategies for Developing Your Bank’s Pandemic Preparedness Plan

Ebola Scare Should Prompt Review of Your Bank’s Pandemic Preparedness Strategy

Health scares like the Ebola virus saturate the news media with concerns about public safety, government response and medical community preparedness. It brings attention to the need for banks to review the strategy in place should operations be compromised by an unforeseen pandemic.

Pandemic planning presents unique challenges to financial institutions. Unlike most natural or technical disasters and malicious acts, the impact of a pandemic is much more difficult to determine because of the anticipated difference in scale and duration. As a result of these differences, no individual or organization is safe from the potential adverse effects of a pandemic event. Experts believe the most significant challenge may be the severe staffing shortages that will likely result from a pandemic outbreak.

Pandemic preparedness should be evaluated, monitored, tested and reported together with the bank’s general disaster recovery/ business continuity preparedness cycle; including business impact analysis and risk assessment processes.Unfortunately, there is no “one size fits all” approach to the pandemic preparedness.

First of all, the pandemic planning is actually opposite to other types of disaster recovery planning because you need to separate people rather than gather them. Also, unlike in a standard recovery, there will not be an issue of technology infrastructure failures, but rather of acute shortage and exposure of trained personnel.

In addition, pandemic planning stresses video conferencing, working from home, reduction of overcrowding and physical proximity. Also, some studies stress the importance of aligning the planning with the company’s profile (i.e. centralized as opposed to business units having certain levels of autonomy etc.).

Below are 4 strategies for developing a pandemic preparedness plan:
Develop a Communication Plan – Determine the delivery method of important news and instructions. This may take form of newsletters, internal web sites, company meetings, etc. There should also be a forum for questions and a method for providing FAQs to all.
Determine the Methodology for a Pandemic Plan – Create a framework of facilities, systems, and procedures that need to continue for critical operations should a large numbers of staff members be unavailable for prolonged periods.
Analyze the Impact of a Pandemic – The analysis of the potential impact of a pandemic should be continual and coordinated with the reporting health organizations. Once a timeline of impact duration is assessed, the maximum impact of the potential disruption can be better assessed.
Put Together a Pandemic Response Team – Because of the unpredictability of a pandemic development and highly contagious nature of the virus, there should be a pandemic team in place who are all familiar with the plan objectives. Team members would be responsible for coordinating all recovery activities to keep banking services and processing to acceptable levels during prolonged times of pandemic-related personnel shortages.
The Business Continuity team at The Broadleaf Group Banking Division has created a 37-point Pandemic Preparation Checklist to help guide clients through the process of planning. A consultant can provide valuable insight with a no-cost assessment of your overall business continuity program. Call 1-866-837-4103 or fill out the form in the right sidebar to get started.
JOIN THE BSA/AML LINKEDIN GROUP

Click this link http://linkd.in/1w9WKP6 to join the Bank Secrecy Act/ Anti-Money Laundering Roundtable Networking Group on LinkedIn. This group serves as an online gathering place for banking professionals to discuss a variety of topics including:

BSA/Officers General Role and Responsibilities
Employee Training
Current Regulatory Challenges
Enhancing the Risk Assessment
Enhancing Risk-Based Approaches to AML

Texas Bankers Association Conference Summary

It was good to see everyone who attended the Texas Bankers Association in April. Balancing banking, business and technology while sampling locally brewed craft beers and munching on brisket tacos made for an enjoyable and informative few days spent in Austin.

In recap, Thursday was spent conversing and listening to several notable speeches. There was plenty of information disseminated, as we attended several presentations including: “Banking Regulatory Examinations: What Bank Directors Need to Know,” the “US Economic Outlook and Trends in Bank M&A and IPO’s” as well as “Bank Robbery Preparedness Training.” If you were not able to attend and want to learn more, please contact us and we will share our notes.

Friday, we had the pleasure of listening to keynote speaker General Michael Hayden, former Director of the CIA and NSA. His presentation on Cyber Threats and Other Dangers was both interesting and informative. Cyber security seemed to be a topic of several conversations and General Hayden addressed the issue of managed service platform and protecting cloud based environments. His speech seemed to resonate with everyone who attended.

Broadleaf Group Banking Division Experts to Attend California Bankers Association Regulatory Compliance Conference

Broadleaf Group Banking Division experts to meet with members of the California Bankers Association at the 37th Annual Regulatory Compliance Conference in Rancho Mirage, CA from October 6-9, 2015. The conference gives participants the opportunity to hear about industry trends including: security topics, compliance issues, risk assessment and more. Consultants from Broadleaf Group Banking Division will be available to meet with attendees to discuss their specific issues relating to SAR, EDD, BSA/AML and other compliance and technology issues. Be sure to ask about earning CAMS credits via our upcoming workshops.

Those unable to attend this year’s conference can attend Broadleaf Group Banking Division’s BSA workshops and quarterly BSA/AML roundtables. Two BSA workshops are scheduled to take place this fall. A SAR-focused workshop takes place on October 14th and an EDD-focused workshop takes place on November 4th. Additionally, planning for the next quarterly BSA/AML roundtable is underway and will take place in November 2015. To stay current on event dates, trending banking news and connect with industry peers, bankers can request membership in the LinkedIn BSA/AML Roundtable Networking Group. https://www.linkedin.com/groups/BSA-AML-Roundtable-Networking-Group-6901137/about

About Broadleaf Group
Broadleaf Group, a proud member of the Reliable IT family of companies, is a leading provider of IT solutions throughout the United States. The Banking Division of Broadleaf Group serves over 300 banks and delivers high value solutions while controlling costs. Services include strategic planning, managed compliance, managed services and cloud-hosted services. The Banking Division understands the complexities of banking regulations and regulatory agencies such as FFIEC, GLBA, BSA/AML, SSAE16 and SOC. With industry app expertise and experience with the vendors that provide them, the team is knowledgeable about Fiserv, Jack Henry, FIS, ITI, Icore and Metavante. Complimentary consultations are available to see if our strategies suit your needs. For more information, visit http://www.BroadleafGroup.com/banking.

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Through the cites of the word in classical

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