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What should your institution learn from the 2016 FIBA conference?

6 key insights on where to focus your AML efforts today


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The annual Florida International Bankers Association (FIBA) conference always offers key insights into the latest trends in anti-money laundering (AML) practices, compliance and regulatory focus. Following are six key insights from the 2016 FIBA conference to help guide your anti-money laundering efforts this year.

1. Lessons learned from enforcement actions.  In 2015 and 2016, the Office of the Comptroller of the Currency (OCC) took 50 formal actions. That’s in addition to memorandums of understanding and other informal actions, which are not publically available. Common issues resulting in enforcement actions fall into three key categories:

  • Internal control weaknesses
  • Transaction monitoring and SAR reporting issues
  • Other general governance concerns

Our white paper offers eight areas your institution can focus on to help avoid regulatory compliance issues.

2. New developments on the AML landscape. Regulators continue to emphasize the need for effective BSA/AML program governance and the central role that a comprehensive, effective risk assessment process has to play. From the key role risk assessments must play in your AML effort to effective escalation processes and documentation to evolving technologies, such as global networks, learn what’s new in AML.

3. AML compliance for broker-dealers. Regulators continue to tighten BSA/AML compliance focus on broker-dealers. Key emerging issues include broker-dealers providing bank-like products without adapting their AML programs to comply with regulatory requirements (e.g., failing to file currency transaction reports and not adapting their monitoring systems to trigger alerts). Regulators are also focusing on cash balance accounts with little or no brokerage activity.

4. SAR trends and issues. Breakdowns of suspicious activity reports (SARs) by the top ten reporting states and by type of institution give an overview of where issues are most prevalent. Some of the most common types of fraud reported in 2015:

  • Tax refund or other tax fraud
  • Check kiting and credit card kiting
  • New account fraud
  • Deposit fraud
  • Pre-paid card fraud
  • Income and employment discrepancies
  • Identity fraud
  • Fraud rings

5. How to file a better SAR.  Learn some of the most common failings in SAR filings and how to avoid them. 

6. Sanctions compliance. Evolving geopolitical realities are complicating compliance with Office of Foreign Asset Control (OFAC) sanctions for many financial institutions. Banks must be sure to back up both specific transaction decisions and their risk analysis involving any customers potentially subject to OFAC sanctions with solid documentation. The three main areas of risk for sanctions compliance are:

  • Trade finance
  • Correspondent banking
  • Transaction monitoring

RSM’s white paper offers additional detail on these six issues, along with links to related thought leadership on key topics.


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