Risk Management​

• Risk Based Approach
• Core Elements
  • The Five Pillars of a Quality AML program
  • Compliance Culture

Case Studies & Regulatory Actions

• Objective:
  • Engage your AML analytical skill set. Strengthen your ability to recognize the 3 W’s, “What Went Wrong”, recognize money laundering methods, identify their financial institution’s vulnerabilities, identify money laundering signals, and understand potential regulatory actions and/or law enforcement engagement.
  • Provide attendees with a road map on how they can best fulfill their role in a quality AML program by informing them of the chain of procedures used by other AML professionals such as regulators and law enforcement. This process provides professionals with an understanding of the mechanisms of an AML program better equipping individuals in the application of their AML responsibilities.
• Real World Application: The AML Training Academy instructor will provide insight on the case studies drawing from his years of experience as a New York State Police Investigator and cross designated federal agent assigned to the position of NY state money laundering coordinator. As NY state’s money laundering coordinator he acted as a liaison between law enforcement and financial institutions. With this unique insight he will impart a first hand account of what law enforcement is looking for from financial institutions and how law enforcement and financial institutions work together to fill their common AML goal.

International Benchmarks

• USA Patriot Act
• Financial Action Task Force (FATF)
• Basel
• Wolfsberg
• Egmont
• European Union (EU) Directives
• Office of Foreign Assets Control (OFAC) / Sanctions

Lunch

Due Diligence

Flex your problem solving muscles and develop your AML analytical skill set to become more effective in your role combating money laundering and reduce the financial crimes risk within your institution or agency.

• Know Your Customer
  • Know Your Customer (KYC) and Customer Identification Program (CIP) policies and procedures.
    • Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD)
    • Counter Terrorism
  • Beneficial Ownership
    • NY Department of Financial Services (DFS) 504
    • Shell Companies
• Transaction Monitoring
  • The Alert System
    • Trigger
    • Review
    • Clear/Escalate
• Suspicious Activity Reporting (SAR)
  • In depth study on the SAR process and how it weaves its way through on boarding, CDD, transaction monitoring, and SAR development. We’ll finish with how and why information is shared with law enforcement and regulators, what law enforcement and regulators do with that information, and why those methods effect AML policy and procedures.
  • Getting to Suspicious/When to File
  • Preparing Quality Narrative
  • What Happens After the SAR

Coordination Of Financial Institutions And Law Enforcement

• Subpoenas / Search Warrants / National Security Letters
• Meetings with Law Enforcement
• The Enemy Within
• Fictitious ID
• Investigators Tool Box
  • Investigators mind set
  • Open source intelligence

Breakout Workshop “You Are the Investigator”

• Objective:
  • Develop participants understanding of money laundering processes through the eyes of an Investigator
  • Provide participants with the big picture via a situational scenario that must be solved using the skills of an investigator. Outlining why policies and procedures are required to protect their institutions and how those AML policies and procedures are utilized in money laundering investigations.
  • Increase participants awareness of the use and importance of AML policies and procedures to safeguard their institutions and the community from criminal activity..
• Real World Application: Review how financial institutions, government agencies, and branches of law assist in deterring criminal activity and help to manage risk..Origin of money laundering

Wrap up