BSA-AML Examiner School - Series 2 eBook

BSA/AML Examiner School – Series 2

October 15-24, 2024 Live Virtual

@ www.csbs.org ♦ @csbsnews

CONFERENCE OF STATE BANK SUPERVISORS 1300 I Street NW / Suite 700 / Washington, DC 20005 / (202) 296-2840

October 15-24, 2024 BSA/AML Examiner School - Series 2 Live Virtual

ATTENDEES American Samoa Office of Financial Institutions Fetui, Samantha

samantha.fetui@tr.as.gov isabelle.maugalei@tr.as.gov

Mauga-Lei, Isabelle

California Department of Financial Protection and Innovation Dolgonos, Ivan

ivan.dolgonos@dfpi.ca.gov wilton.edwards@dfpi.ca.gov shubo.jiang@dfpi.ca.gov george.lai@dfpi.ca.gov randall.shem@dfpi.ca.gov maria.shimohara@dfpi.ca.gov samson.tran@dfpi.ca.gov

Edwards, Wilton Jiang, Shubo Lai, George Shem, Randall Shimohara, Maria

Tran, Samson

Illinois Department of Financial & Professional Regulation Fitch, Sammy

sammy.l.fitch@illinois.gov

Fortune-Perry, Cynthia

cynthia.fortune-perry@illinois.gov frank.kaufmann@illinois.gov george.nelson2@illinois.gov

Kaufmann, Frank Nelson, George

Weiss, jason

jason.weiss@illinois.gov

Maryland Office of Financial Regulation Brown, Sabrina

sabrina.brown@maryland.gov

Michigan Department of Insurance and Financial Services Boomer, Richard (RK)

boomerr@michigan.gov thebob@michigan.gov

Thebo, Bradley

Minnesota Department of Commerce Omar, Ayan

ayan.omar@state.mn.us

Missouri Division of Finance Rigdon, Kayleigh

kayleigh.rigdon@dof.mo.gov

New York State Department of Financial Services Albreada, Alyssa

alyssa.albreada@dfs.ny.gov theresa.browne@dfs.ny.gov marlene.delamothe@dfs.ny.gov kimisha.ellington@dfs.ny.gov

Browne, Theresa

Delamothe-Bourne, Marlene

Ellington, Kimisha

Frett, Lewia Steans, Jessica

lewia.frett@dfs.ny.gov jessica.steans@dfs.ny.gov

South Dakota Division of Banking Hardwick, Michael

michael.hardwick@state.sd.us ashley.knoff@state.sd.us megan.lindely@state.sd.us mattp.morgan@state.sd.us

Knoff, Ashley Lindely, Megan Morgan, Matthew

INSTRUCTORS California Department of Financial Protection & Innovation Khatchadourian, Sandra Mississippi Department of Banking and Consumer Finance Sisco, Michael

sandra.khatchadourian@dfpi.ca.gov

michael.sisco@dbcf.ms.gov

Nebraska Department of Banking and Finance Koerner, Jaunita West Virginia Division of Financial Institutions McVey, Tom

jaunita.koerner@nebraska.gov

tmcvey@wvdob.org

CSBS STAFF Hoyle, Katie

khoyle@csbs.org

Richardson, Amy Romano, Chris

arichardson@csbs.org cromano@csbs.org

BSA/AML Examiner School – Series 2 Live Virtual October 15-24, 2024

Tuesday, October 15, 2024

Introduction & Pre-Course Review BSA/AML Compliance Program

1:00 pm – 1:45 pm 1:45 pm – 2:15 pm 2:15 pm – 2:30 pm 2:30 pm – 4:00 pm

Break

Core Exam Procedures

Wednesday, October 16, 2024

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, October 17, 2024

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 – 3:45 pm 3:45 pm – 4:00 pm

Break

Core Exam Procedures

Instructions for BSA Officer Interviews

Tuesday, October 22, 2024

Core Exam Procedures/Interview Preparation BSA Officer Interviews (Break Included)

1:00 pm – 2:00 pm 2:00 pm – 4:00 pm

Wednesday, October 23, 2024

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, October 24, 2024

Emerging Issues

1:00 pm – 2:30 pm 2:30 pm – 2:45 pm 2:45 pm – 3:45 pm 3:45 pm – 4:00 pm

Break

Emerging Issues

Final Assessment & Wrap Up

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BSA/AML Examiner School – Series 2 October 15-24, 2024

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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

Sandra Khatchadourian

Senior Financial Institutions Examiner California Department of Financial Protection & Innovation sandra.khatchadourian@dfpi.ca.gov

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Instructor Contact Information

Training Specialist Mississippi Department of Banking and Consumer Finance michael.sisco@dbcf.ms.gov Michael Sisco

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Instructor Contact Information

BSA Examiner Specialist Nebraska Department of Banking and Finance jaunita.koerner@nebraska.gov Jaunita Koerner

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Instructor Contact Information

Chief Financial Institutions 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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BSA/AML Compliance Program

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•Internal Controls •Independent Testing •BSA Compliance Officer •Training •Customer Due Diligence BSA/AML Compliance Program

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Internal Controls

Review of the bank’s written policies, procedures, and processes.

Board of Directors ultimately responsible.

Designed to limit and control risks and to achieve compliance. Commensurate with the size, structure, risks, and complexity of the bank.

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Internal Controls

Identify banking operations more

Inform the board of deficiencies and of SARs filed.

Identify a person responsible for BSA/AML compliance.

Meet all regulatory recordkeeping and reporting requirements.

Provide for program continuity.

vulnerable to abuse by money launderers and criminals.

Provide sufficient controls and monitoring systems for timely reporting of suspicious activity.

Provide sufficient controls and systems for filing CTRs and CTR exemptions.

Implement risk-based CDD policies, procedures, and processes.

Identify reportable transactions.

Provide for dual controls.

Train employees to be aware of their responsibilities under the BSA regulations and internal policy guidelines.

Incorporate BSA compliance into job descriptions and performance evaluations.

Provide for adequate supervision of employees.

The above list is not designed to be all-inclusive and should be tailored to reflect the bank’s BSA/AML risk profile.

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Independent Testing

•Conducted by the internal audit department, outside auditors, consultants, or other qualified independent parties. •Conducted generally every 12 to 18 months. •Perform testing for specific compliance with the BSA. •Risk-based and evaluate the quality of risk management. •Cover all of the bank’s activities. •Testing should be reported directly to the Board or Committee.

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Independent Testing

Appropriate risk-based transaction testing to verify the bank’s adherence to the BSA recordkeeping and reporting requirements.

An evaluation of the overall adequacy and effectiveness of the BSA/AML compliance program

A review of the bank’s risk assessment for reasonableness given the bank’s risk profile.

An evaluation of management’s efforts to resolve violations and deficiencies.

A review of the effectiveness of the suspicious activity monitoring systems.

An assessment of the overall process for identifying and reporting suspicious activity

An assessment of the integrity and accuracy of MIS used in the BSA/AML compliance program

A review of staff training.

Any violations, policy or procedures exceptions, or other deficiencies should be included in an audit report

The board or designated committee and the audit staff should track audit deficiencies and document corrective actions.

All audit documentation and workpapers should be available for examiner review.

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Compliance Officer

Designated by the bank’s board of directors Responsible for coordinating and monitoring day-to-day BSA/AML compliance. Managing all aspects of the BSA/AML compliance program. May delegate BSA/AML duties to other employees The board of directors is responsible for ensuring that the BSA compliance officer has sufficient authority and resources. Fully knowledgeable of the BSA and all related regulations. Understand the bank’s products, services, customers, entities, and geographic locations, and the potential risks. Pertinent BSA-related information should be reported to the board of directors.

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Training

Training should include regulatory requirements and the bank’s internal BSA/AML policies, procedures, and processes.

Ensure that appropriate personnel are trained in applicable aspects of the BSA.

The training should be tailored to the person’s specific responsibilities

Training should encompass information related to applicable business lines

The board of directors need to understand the importance of BSA/AML regulatory requirements, the ramifications of noncompliance, and the risks posed to the bank.

Changes to internal policies, procedures, processes, and monitoring systems should also be covered during training.

Training should be ongoing and incorporate current developments.

The BSA compliance officer should receive periodic training.

Banks should document their training programs.

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CDD Requirements

• Obtaining and analyzing sufficient customer information to understand the nature and purpose of customer relationships for the purpose of developing a customer risk profile; and • Conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information, including information regarding the beneficial owner(s)of legal entity customers.

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Questions

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BSA Officer Interviews

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Session Learning Objectives: 1. Prepare to

conduct effective interviews of the BSA Officer

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Session Learning Objectives: 2. Identify techniques for BSA Officer meetings

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Session Learning Objectives: 3. Apply concepts

by interviewing and evaluating the BSA Officer

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BSA Officer Interviews

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BSA Officer Interviews

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BSA Officer Interviews • Assess whether the individual is competent • knowledge of BSA & related regulation • implementation of the compliance program • Does the individual have appropriate authority, independence & access to resources (staffing & systems)? • Ask questions about exam materials

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BSA Officer Interviews

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BSA Officer Interviews

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1. Preparedness 2. Control of discussion 3. Confidence 4. Focus on the most important issues 5. Organization BSA Officer Interviews

6. Follow up questions 7. Minimize distractions

8. Etiquette for effective web meetings 9. Consideration for time constraints 10.Close the meeting

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Assignment

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Questions

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MSB’s, Money Transmitters & Prepaid Access

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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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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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Questions

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MSB’s, Money Transmitters & Prepaid Access

Remember – these types of customers are not bad, just can be higher risk and must be managed!

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Exam Results

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Session Learning Objectives: 1. Discuss developing a supervisory response & communicating findings

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Session Learning Objectives: 2. Apply concepts to exam exercises

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Exam Results

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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

The examiner should:

• Develop and document conclusions about the BSA/AML compliance program’s adequacy. • Discuss preliminary conclusions with EIC and bank management. • Present these conclusions in a written format for inclusion in the report of examination (ROE). • Determine and document what regulatory response, if any, is appropriate. • Evaluate the thoroughness and reliability of any risk assessment conducted by the bank.

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Exam Results Reach a preliminary conclusion as to whether the following requirements are met: • The BSA/AML compliance program is effectively monitored and supervised in relation to the bank’s risk profile. • The BSA/AML compliance program is effective in mitigating the bank’s overall risk. • The board of directors and senior management are aware of BSA/AML regulatory requirements.

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Exam Results

•BSA/AML policies, procedures, and processes •Internal controls •Independent testing

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Exam Results • The designated person responsible for coordinating and monitoring day-to-day compliance is competent and has the necessary resources. • Personnel are sufficiently trained to adhere to legal, regulatory, and policy requirements. • Information and communication policies, procedures, and processes are adequate and accurate. • All relevant determinations should be documented and explained.

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Exam Results

Management has not assessed, or has not accurately assessed, the bank’s BSA/AML risks.

Management is unaware of relevant issues.

Management is unwilling to create or enhance policies, procedures, and processes.

Management or employees disregard established policies, procedures, and processes.

Management or employees are unaware of or misunderstand regulatory requirements, policies, procedures, or processes.

Higher-risk operations (products, services, customers, entities, and geographic locations) have grown faster than the capabilities of the BSA/AML compliance program.

Changes in internal policies, procedures, and processes are poorly communicated.

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Exam Results

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Exam Results Document workpapers appropriately with the following information: • A conclusion regarding the adequacy of the BSA/AML compliance program • Whether it meets all the regulatory requirements by providing the following: • A system of internal controls

• Independent testing for compliance • A specific person to coordinate and monitor the BSA/AML compliance program • Training of appropriate personnel • The CDD Rule

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Exam Results In some cases, the appropriate regulatory response will include the citation of a regulatory violation.

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Exam Results

In appropriate circumstances, an agency may take either informal or formal enforcement actions to address violations of the BSA requirements.

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Exam Results Isolated or technical violations are limited instances of noncompliance with the BSA that occur within an otherwise adequate system of policies, procedures, and processes.

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Exercise

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Questions

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Emerging Issues

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Session Learning Objectives: 1. Discuss current issues relevant to BSA/AML

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Emerging Issues

• FinCEN Priorities • CRBs • Human Trafficking • BaaS – Banking as a Service • AI & Machine Learning • FinCEN Portal Updates

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FinCEN Priorities

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FinCEN Priorities 1. Corruption 2. Cybercrime 3. Terrorist Financing 4. Fraud 5. Transnational Criminal Organization Activity 6. Drug Trafficking Organization Activity 7. Human Trafficking & Human Smuggling 8. Proliferation Financing

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Cannabis-Related Businesses (CRBs)

Terminology: • Cannabis • Marijuana • Hemp

• THC • CBD

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Cannabis-Related Businesses (CRBs)

February 9, 2024

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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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BaaS – Banking as a Service BaaS partnerships differ from traditional vendor relationships in a variety of ways, notably in that they can present substantially higher degrees of risk. Accordingly, fintech partner oversight will form the core of the Bank’s future Third Party Risk Managment program.

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BaaS – Banking as a Service The FI should develop robust governing documentation to support the program. In particular, policy and program documents relating to Bank’s fintech partner oversight program should clearly address: • Roles and responsibilities • Reporting lines (board oversight and governance) • Testing and ongoing monitoring • Risk assessments • Partner due diligence and onboarding • Contractual safeguards • Contingency plans • Internal and external audits

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AI & Machine Learning Technological advances in AML monitoring systems • AI, Machine Learning, other forms • BSA Officer responsibility

• AML Software • Fintech Partner • Fintech Customer • Trends • Discussion with examiners

STATE OF CALIFORNIA Department of Financial Protection and Innovation GOVERNOR Gavin Newsom · COMMISSIONER Clothilde V.Hewlett

The information discussed today does not represent the direct views or opinions of DFPI, but rather the examiner’s interpretation and opinion.

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FINCEN Platforms FinCEN created two new and separate platforms

A. New platform CTRs, SARs and all reported data by FIs - Analyze data to ensure accuracy - 314(a) reports issues still are a concern A. New platform for Beneficial Ownership Information (National database with 3 phases) 1. Registration 2. Access 3. 2025 CDD will be reviewed

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Questions

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BSA/AML School Chatbot Text “bsaschool” to (240) 226-1778

• Training Reinforcement • Knowledge check questions • Helpful resources and tips

Learning Roadmaps

The CSBS Learning Roadmaps are tools to help guide examiners through their learning journey by identifying skill gaps and training opportunities. These tools can also help examiners determine what training is needed to earn formal certification. Available Learning Roadmaps Bank Safety & Soundness Examiners BSA/AML Examiners IT/Cybersecurity Examiners

Developing the Workforce of Tomorrow One of the CSBS strategies is to contribute to innovative learning solutions and develop capabilities that enhance examiner skillsets and promote networked supervision resulting in a high performing, collaborative, and trusted state regulatory workforce.

Money Service Business (MSB) Examiners Mortgage/Non-Depository Examiners Trust Examiners

LearningRoadmaps@csbs.org www.csbs.org/examiner-learning-roadmaps

CSBS Accreditation

CSBS Certification The CSBS Examiner Certification Program recognizes the professionalism and unique skillsets of state regulators and is open to all who meet the education and experience qualifications for a credential. 31 Certification Credentials Safety & Soundness

The CSBS Accreditation Program evaluates state bank, mortgage and money transmitter regulatory agencies against standards set forth by a committee of state regulators. Benefits of Accreditation

Developing the Workforce of Tomorrow One of the CSBS strategies is to contribute to innovative learning solutions and develop capabilities that enhance examiner skillsets and promote networked supervision resulting in a high performing, collaborative, and trusted state regulatory workforce.

Creates Supervision Framework Promotes Process Standardization Builds Trust Improves Information Sharing Keeps States Accountable Recognizes Agencies Performance

Mortgage Licensing Trust IT & Cybersecurity Data Analytics Training

certification@csbs.org csbs.org/examiner-certification

accreditation@csbs.org csbs.org/department-accreditation

Education or training which has been determined to be essential in maintaining and enhancing skills or knowledge necessary for the performance of a job for which the certification is required. Continuing Education Classifications Core Education, training, or other activities which has been determined will enhance skills or knowledge necessary to effectively work as an examiner or regulator including but not limited to soft skills, technical trainings, providing on the-job training, participating on CSBS committees. Training completed as part of employment or general interests but does not directly contribute to the proficiency of the certification maintained. General courses will not count toward continuing education. General Elective

Providing a Path

Certification can assist agencies in developing the workforce of tomorrow by providing a framework for career progression and professional development.

Continuing education to take state regulators to the next level.

Training directors decide what their examiners need Tie in training to certifications Certification as a measure for career progression

Acquiring and maintaining a CSBS Certification gives regulators the opportunity to advance their career along a well-defined career path, encourages knowledge and skills development and recognizes and rewards achievement.

Training Directors will be able to identify courses that align with an examiners credential, maintaining the education and career path provided by their agency in combination with a CSBS certification. Program Improvements