“We are working to level the playing field. We want to be sure everyone is playing by the same rules. Everyone playing by the same rules will improve the overall AML system in the United States and make the United States safer from organized crime and terrorism. Everyone playing by the same rules will reward those financial institutions who do put in the time and money to get it right – by forcing those who cut corners to pay a price for that choice”.
~ Jennifer Shasky Calvery, Director Financial Crimes Enforcement Network, February 13, 2013
Recent enforcement actions for failures in BSA compliance read like a “who’s who” of financial players, ranging from the largest of the large while not leaving out community-sized financial institutions, and including personal penalties imposed on board members. Three new revised forms being implemented April 1st, anticipated proposals on beneficial ownership and customer due diligence, the interdependent components of an effective SAR program, the constant focus on the completeness of risk assessments, the possibility of an exam update, and the ever-changing menu of new products and services continue to challenge even the most tenured BSA compliance professional. The upcoming two-day IBA Anti-Money Laundering and Bank Secrecy Act School will cover these and other issues, opportunities, and expectations in the arena of Bank Secrecy Act compliance.
Mark W. Dever, AAP, CAMS, is a Senior Consultant with Professional Bank Services, Inc. (PBS). PBS offers consulting and educational seminars for Bank Compliance Services for the financial industry. Mark has lectured at regional and national seminars and at graduate schools of banking hosted by various bank associations and national industry groups. Mark will present the two-day IBA Anti-Money Laundering and Bank Secrecy Act School on April 15-16 in Johnston.