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Final CDD Rule: The Nexus of BSA and Operations - 2017
Victor Cardona Recorded on December 6, 2017
The impending Final CDD Rule breaks out parts of the BSA into the new 5th Pillar. Many of the requirements of the Final CDD Rule are already being practiced in theory by financial institutions, while other financial institutions are grappling with implementing new procedures to meet the new requirements. Pushback for more “BSA stuff” from the frontline is a common hurdle for BSA officers. However, much of the information that is already being collected as part of the Customer Identification Program (CIP) and Know Your Client (KYC) process can be leveraged to meet the new requirements, but additional process will still need to be implemented and reevaluated to ensure ongoing compliance.
This webinar will examine the information or documentation already being collected and its use to meet the 5th-Pillar standards. An example of a new accounts workflow review will be illustrated to show at what stage of the new accounts process certain CDD information is collected and can be leveraged. A sample review of policy and procedures will be shown from both the frontline/operational and the BSA perspective to ensure the new CDD process is implemented and sustained over time.
This webinar will cover:
Core elements of the Final CDD Rule
Operational and BSA policy and procedures, including workflows
New Accounts documentation review, including convoluted business structures
Triggering events/ event-based account reviews
Certifications of Beneficial Ownership (CBO)
Victor is currently Vice President of the BSA Department at Opus Bank, a $7.5 billion bank headquartered in Irvine, Ca. Victor has been in banking since 2004, specializing in BSA/AML compliance since 2005. In 2015 and 2016, Victor served on the faculty of the BankersOnline BSA/AML Top Gun Conferences. Victor is responsible for managing Opus Bank's enterprise wide BSA Risk Assessment program, Quality Control program, policies and procedures, and training. Prior to this, Victor was the BSA Officer for Plaza Bank, a $1.1 billion bank in Irvine, Ca. He was responsible for managing Plaza Bank's overall BSA/AML and OFAC compliance program. Before joining Plaza Bank, Victor was the Assistant Vice President, BSA Risk Officer for City National Bank, a $35 billion bank in downtown Los Angeles where he performed the testing of the bank's BSA/AML and OFAC risk assessment program. He was promoted to this position within City National from Senior Compliance Analyst where Victor investigated the bank's most complex and high-profile SAR investigations. Victor started his banking career with Farmers & Merchants Bank of Long Beach as a teller before quickly moving into their BSA Department. While at Farmers & Merchants Bank, Victor also represented the bank as the Financial Institution Liaison with the Long Beach Elder Abuse Prevention Team. Victor received his Bachelor's Degree from Cal State Dominguez Hills in Accounting and his MBA from Utica College in Economic Crime & Fraud Management. Victor also attended the police academy at the Golden West College Criminal Justice Training Center where he received a Certificate of Achievement in Criminal Justice. He has been a member of ACAMS since 2007 and received his certification as a Certified Anti-Money Laundering Specialist in 2008. Victor also sits on the Executive Board for the ACAMS Southern California Chapter.