Ongoing reviews of high-risk customers have been required since FinCEN's first exam manual in 2005, and CDD/EDD guidance further defines how institutions should identify and evaluate them. Regulators, however, have not spelled out the day-to-day approach.
This 60-minute BSA/AML high-risk customer training fills that gap with practical steps to meet both the letter and the spirit of the rules. Drawing on real audit findings, it shows what many banks get wrong and what to do instead.
You'll review FinCEN, FATF and FFIEC requirements, what to include in your high-risk program, current issues, recent enforcement actions, and real-life review examples you can adapt.
Weak high-risk customer programs draw examiner and regulator criticism and enforcement actions. This session helps you identify existing and new high-risk customers properly, use internal knowledge efficiently and run reviews that add real value to your BSA program.
It suits front-line BSA/AML and account opening staff, BSA/AML and compliance officers, risk managers, auditors and consultants.
Weak high-risk customer programs draw examiner and regulator criticism and enforcement actions. This session helps you identify existing and new high-risk customers properly, use internal knowledge efficiently and run reviews that add real value to your BSA program.
It suits front-line BSA/AML and account opening staff, BSA/AML and compliance officers, risk managers, auditors and consultants.
Thomas Nollner
Thomas E Nollner has more than 35 years of experience in financial institution supervision and consulting. Mr. Nollner spent 30 years as a National Bank Examiner for the Comptroller of the Currency where he was a safety and soundness examiner and a compliance examiner. As a safety and soundness examiner he examined national banks for capital adequacy, asset quality, management issues, earnings concerns, and liquidity funding. As a compliance examiner, he examined national banks for compliance with consumer laws and regulations such as the Truth-in-Lending Act, the Real Estate Settlement Procedures Act, the Flood Disaster Protection Act, the Community Reinvestment …
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