BSA-AML Examiner School Series 2 May 2022
BSA/AML Examiner Training - Series 2
May 31 - June 9, 202 2
@ www.csbs.org � @csbsnews
CONFERENCE OF STATE BANK SUPERVISORS 1129 20th Street NW / 9th Floor / Washington, DC 20036 / (202) 296-2840
BSA/AML Examiner School – Series 2 Live Virtual May 31 – June 9, 2022
Tuesday, May 31, 2022
Introduction & Pre ‐ Course Review
1:00 pm – 1:45 pm 1:45 pm – 2:30 pm 2:30 pm – 2:45 pm 2:45 pm – 4:00 pm
Core Exam Procedures
Break
Core Exam Procedures
Wednesday, June 1, 2022
Prior Class Review Core Exam Procedures
1:00 pm – 1:15 pm 1:15 pm – 2:30 pm 2:30 pm – 2:45 pm 2:45 pm – 4:00 pm
Break
Core Exam Procedures
Thursday, June 2, 2022
Prior Class Review Core Exam Procedures
1:00 pm – 1:15 pm 1:15 pm – 2:30 pm 2:30 pm – 2:45 pm 2:45 pm – 4:00 pm
Break
Core Exam Procedures
Tuesday, June 7, 2022
BSA Officer Interviews BSA Officer Interviews
10:00 am – 11:30 am 1:30 pm – 4:00 pm
Wednesday, June 8, 2022
Review Day 3 & 4
1:00 pm – 1:15 pm 1:15 pm – 2:30 pm 2:30 pm – 2:45 pm 2:45 pm – 4:00 pm
Money Transmitters & Prepaid Access
Break
Exam Results
Thursday, June 9, 2022
Final Assessment Emerging Issues
1:00 pm – 1:30 pm 1:30 pm – 2:30 pm 2:30 pm – 2:45 pm 2:45 pm – 4:00 pm
Break
Emerging Issues
Virtual BSA/AML Examiner School Series 2 - Day 1
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Zoom
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BSA/AML School Chatbot Text “bsaschool” to (240) 226-1778
• Training Reinforcement • Knowledge check questions • Helpful resources and tips
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Introductions
NAME
STATE AGENCY
YEARS OF EXAM
FUN FACT ABOUT YOURSELF
SOMETHING YOU HOPE TO LEARN DURING THIS CLASS
EXPERIENCE & WITH BSA
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Instructor Contact Information
Certified Senior Bank Examiner Arkansas State Bank Department jpowell@banking.state.ar.us Jack Powell
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Instructor Contact Information
BSA Examiner Specialist Nebraska Department of Banking & Finance Jaunita.Koerner@nebraska.gov Jaunita Koerner
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Instructor Contact Information
Case Manager Kentucky Department of Financial Institutions Jessica.Southworth@ky.gov Jessica Southworth
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Instructor Contact Information
Senior Examiner West Virginia Division of Financial Institutions TMcVey@wvdob.org Tom McVey
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Go to www.kahoot.it and enter Game PIN provided
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Session Learning Objectives: 1. Discuss core
Bank Secrecy Act/Anti-Money Laundering concepts
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Session Learning Objectives: 2. Understand how to assess compliance with statutory and regulatory requirements
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Session Learning Objectives: 3. Discuss how to evaluate an OFAC compliance program
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Session Learning Objectives: 4. Apply concepts to exam exercises
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Presentation
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BSA/AML Compliance Program
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BSA/AML Compliance Program
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BSA/AML Compliance Program
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BSA/AML Compliance Program
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BSA/AML Compliance Program
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BSA/AML Compliance Program
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Core Examination Procedures
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Go to www.menti.com and use the code
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Questions
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Virtual BSA/AML Examiner School Series 2 - Day 2
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Go to www.kahoot.it and enter Game PIN provided
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Session Learning Objectives: 1. Understand how to assess compliance with statutory and regulatory requirements
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Session Learning Objectives: 2. Apply concepts to exam exercises
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Core Examination Procedures
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Go to www.menti.com and use the code
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BSA/AML School Chatbot Text “bsaschool” to (240) 226-1778
• Training Reinforcement • Knowledge check questions • Helpful resources and tips
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Questions
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Virtual BSA/AML Examiner School Series 2 - Day 3
1
Go to www.kahoot.it and enter Game PIN provided
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Session Learning Objectives: 1. Understand how to assess compliance with statutory and regulatory requirements
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Session Learning Objectives: 2. Apply concepts to exam exercises
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Session Learning Objectives: 3. Prepare to
conduct effective interviews of the BSA Officer
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Session Learning Objectives: 4. Identify techniques for BSA Officer meetings
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Session Learning Objectives: 5. Apply concepts
by interviewing and evaluating the BSA Officer
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Core Examination Procedures
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Go to www.menti.com and use the code
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BSA Officer Interviews
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BSA Officer Interviews
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BSA Officer Interviews
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BSA Officer Interviews
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BSA Officer Interviews
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BSA Officer Interviews
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Assignment
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BSA/AML School Chatbot Text “bsaschool” to (240) 226-1778
• Training Reinforcement • Knowledge check questions • Helpful resources and tips
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Questions
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Virtual BSA/AML Examiner School Series 2 - Day 5
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Go to www.kahoot.it and enter Game PIN provided
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Session Learning Objectives: 1. Understand how to
assess systems managing risks related to money transmitters & prepaid access
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Session Learning Objectives: 2. Understand how to formulate conclusions about the BSA/AML compliance program
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Session Learning Objectives: 3. Discuss developing a supervisory response & communicating findings
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Session Learning Objectives: 4. Apply concepts to exam exercises
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Money Transmitters & Prepaid Access
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Money Services Businesses (MSB) Definition Doing business in one or more of the following:
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Money Services Businesses (MSB)
Definition Doing business in one or more of the following: • Money Transmitter
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Money Services Businesses (MSB) Definition Doing business in one or more of the following: • Money Transmitter • IVTS
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Money Services Businesses (MSB) Definition Doing business in one or
more of the following: • Money Transmitter • IVTS • Currency dealer/exchanger
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Money Services Businesses (MSB) Definition Doing business in one or more of the following: • Money Transmitter • IVTS • Currency dealer/exchanger • Check casher
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Money Services Businesses (MSB) Definition Doing business in one or more of the following: • Money Transmitter • IVTS • Currency dealer/exchanger • Check casher • Issuer/seller of monetary instruments or prepaid access
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Money Services Businesses (MSB) Definition Doing business in one or more of the following: • Money Transmitter • IVTS • Currency dealer/exchanger • Check casher • Issuer/seller of monetary instruments or prepaid access • U.S. Postal Service
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Money Services Businesses (MSB) Thresholds
>$1,000 for any person on any day in currency, monetary or other instruments: • Foreign exchange dealers • Check cashers • Issuer/seller of monetary instruments
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Money Services Businesses (MSB)
Thresholds >$10,000 to any person during one day without policies and procedures to prevent such a sale: • Seller of prepaid access
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Money Services Businesses (MSB) Money Transmitting Occurs when funds are
transferred on behalf of the public by any and all means, including, but not limited to, transfers within the United States or to locations abroad by wire, check, draft, facsimile, or courier.
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Money Services Businesses (MSB)
Money Transmitting • FinCEN Registration Requirement
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Money Services Businesses (MSB)
Money Transmitting • Unlicensed activity
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Money Services Businesses (MSB)
Money Transmitting • No activity threshold
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Money Services Businesses (MSB) Exceptions
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Money Services Businesses (MSB)
Exceptions • Bank
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Money Services Businesses (MSB)
Exceptions • SEC/CFTC regulated
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Money Services Businesses (MSB)
Exceptions • Regulatory
oversight already in place
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Money Services Businesses (MSB)
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Money Services Businesses (MSB) Examinations • IRS
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Money Services Businesses (MSB) Examinations • States
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Money Services Businesses (MSB) Examination Materials • Fincen.gov/msb- examination-materials
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Money Services Businesses (MSB)
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Money Transmitters
Basic Business Model:
Money Transmitter
Sender
Recipient
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Money Transmitters
Business Model – Agent Included:
Money Transmitter
Branch or Agent
Sender
Receiving Agent
Recipient
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MSB BSA Requirements
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MSB BSA Requirements
FinCEN Registration: • Initial 180 days after established or money transmission began
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MSB BSA Requirements
FinCEN Registration: • Renew every 2 years
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MSB BSA Requirements
FinCEN Registration: • Re-registration requirements • Ownership or control changes • Transfer of voting power • Increase in agents • Within 180 days of change
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MSB BSA Requirements
AML Program: • Internal Controls • Individual Responsible • Training • Independent Review
(look familiar?)
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MSB BSA Requirements
Reporting - CTRs • Currency transactions >$10,000
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MSB BSA Requirements
Reporting - CTRs • 15 days after
transaction date
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MSB BSA Requirements
Reporting - SARs • Involves at least $2,000
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MSB BSA Requirements
Reporting - SARs • MT knows or suspects no
business/lawful purpose
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MSB BSA Requirements
Reporting - SARs • 30 days after initial detection
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MSB BSA Requirements
Reporting - SARs • Issuers of
money orders or traveler’s checks
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MSB BSA Requirements
Reporting - Other
• Report of International Transportation of Currency or Monetary Instruments (CMIRs) • Report of Foreign Bank and Financial Accounts (FBARs)
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MSB BSA Requirements
• Guidance • Risk Considerations • Recordkeeping • Law Enforcement Requests
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MSB BSA Requirements
• Guidance • Risk Considerations • Recordkeeping • Law Enforcement Requests
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MSB BSA Requirements
• Guidance • Risk Considerations • Recordkeeping • Law Enforcement Requests
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MSB BSA Requirements
• Guidance • Risk Considerations • Recordkeeping • Law Enforcement Requests
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Prepaid Access • Definition • Open Loop • Closed Loop
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Prepaid Access • Definition • Open Loop • Closed Loop
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Prepaid Access • Definition • Open Loop • Closed Loop
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Bank Exam Procedures
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Bank Exam Procedures
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Bank Exam Procedures
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Bank Exam Procedures
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Bank Exam Procedures
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Bank Exam Procedures
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Bank Exam Procedures
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Bank Exam Procedures
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Bank Exam Procedures
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Exercise
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Go to www.menti.com and use the code
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Exam Results
Assess adequacy of the bank’s BSA/AML compliance program.
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Exam Results
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Exam Results
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Exam Results
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Exam Results
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Exam Results
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Exam Results
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Exam Results
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Exam Results
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Exercise
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Questions
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Virtual BSA/AML Examiner School Series 2 - Day 6
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BSA/AML School Chatbot Text “bsaschool” to (240) 226-1778
• Training Reinforcement • Knowledge check questions • Helpful resources and tips
2
Final Assessment
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Session Learning Objectives: 1. Discuss current issues relevant to BSA/AML
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Emerging Issues
• Cryptocurrency • FinCEN Priorities • COVID Impact • CRBs • Human Trafficking
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Cryptocurrency
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Go to www.menti.com and use the code
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FinCEN Priorities
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COVID Impact
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Cannabis-Related Businesses (CRBs)
Terminology: • Cannabis • Marijuana • Hemp
• THC • CBD
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Cannabis-Related Businesses (CRBs)
https://disa.com/map ‐ of ‐ marijuana ‐ legality ‐ by ‐ state
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Cannabis-Related Businesses (CRBs)
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Cannabis-Related Businesses (CRBs)
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Cannabis-Related Businesses (CRBs)
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Cannabis-Related Businesses (CRBs)
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Human Trafficking in Financial Accounts
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https://traffickingresourcecenter.org/
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Questions
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