This webinar will highlight the steps to identify and evaluate high-risk customers. Learn how to perform BSA, AML risk assessments.
Why Should You Attend:
The management of compliance risk requires a thorough evaluation of the customer base. Determining the risk rating of a customer – especially those seen as High Risk – plays an important role in the construction of a complete and accurate BSA/AML Risk Assessment. The determination of High Risk Customers may involve a wide array of variables, carefully rated and scored, or a single variable that overrides all others. The factors to calculate high risk – or any risk – must drive an on-boarding system – computer-based or manual. How many high-risk customers must an institution have before the meaning of high risk becomes meaningless? The USA Patriot Act has laid out the requirements for Customer Due Diligence and Enhanced Due Diligence for High Risk customers. The recently implemented FinCEN CDD Rule which formalized the concept of beneficial ownership, provides guidance for the management of high risk customers.
This webinar will examine the regulatory background behind the determination of high risk, weighting and rate factors leading to high risk scoring, and asking when is a high-risk customer too hot to handle, what is the risk appetite of the institution.
Learning Objectives:
- High Risk Customers and the BSA/AML Risk Assessment
- What makes a Customer High Risk – Institutional Risk Appetite
- Evaluating and Validating Rating Factors
- Enhanced Due Diligence Considerations
- Can an Institution have too Many or too Few High-Risk Customers
Areas Covered in the Webinar:
- The Customer Risk Rating Profile
- What is High Risk?
- The On-boarding System
- The BSA/AML Risk Assessment
- Country Risk Ratings
Who Will Benefit:
- BSA/AML Officers
- Compliance Officers
- Chief Compliance Officers
- Sanctions Officers
- AML Analysts
- Chief Risk Officers
- Legal Departments Personnel
- Risk Managers
- CEO/Presidents at Banks
- Broker-Dealers
- Money Services Businesses
Instructor Profile:
William Schlameuss has over 20 years’ experience in regulatory compliance, including BSA/AML/OFAC. He has worked with a wide range of US branches of major foreign banking organizations from all continents, both as chief compliance officer and compliance consultant. He has a prior background in IT as manager and implementer of core banking and payment systems, as well as compliance-related systems.
Mr. Schlameuss has extensive experience with State and Federal Banking regulators in examination preparation, assistance and response, including assistance in the remediation of written agreements for clients.
As a project manager Mr. Schlameuss has led BSA/AML audits, BSA/OFAC Model Validations, remediation efforts of BSA audit issues, and BSA/OFAC look-backs for international banks, both self-imposed and directed by regulatory authorities. Model Validations included Prime, FCRM, Patriot Officer, Actimize, and eGIFTS.
He has conducted the Annual 3130 Supervisory Reviews for Broker-Dealers of the US branches of major FBOs. Mr. Schlameuss is also a member of the Association of International Bank Auditors and the International Bank Regulatory Compliance Committee.