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Course description

Whether your institution is considering making the jump from manual reports and spreadsheets to an automated monitoring system or you have a system that you have been using for years, this webinar will have something for you.

We will not endorse one vendor over another, but we will discuss the key components of your vendor management program that can help make sure you pick the system that is best suited for your institution. Every system has its limitations. We will cover steps you can take to identify and document these limitations so that you can develop procedures for monitoring activity that your system does not.

Your vendor may make recommendations for customizing system settings, but the responsibility for the system's accuracy in identifying suspicious activity ultimately rests with the institution. Using current guidance we will give you tips for analyzing your customer's activity to help establish system parameters.

Strong policies and procedures establish accountability for maintaining and operating an AMS. Who manages alerts? What is the appropriate timetable for reviewing alerts? How are alert resolutions documented? We will address examiner expectations and best practices.

Once your system is up and running, examiners will expect that the system is independently validated in order to ensure that the model is reasonably designed based on the unique risks of your institution. We will cover the current guidance to help you know what to expect during a validation and what questions your examiners may ask.

In this two hour session, Brian will cover: 

  • Vendor Management
  • System Implementation
  • Model Policy
  • GAP Analysis
  • Customer risk rating settings
  • Rule Settings
  • OFAC & 314(a) Processing
  • Change Control
  • Model Validation preparation
  • 2005 FDIC Model Governance
  • 2011 FRB/OCC Model Validation Guidance

Written materials will be provided for the listener to refer to during the presentation.

BSA Officers, BSA Analysts, IT Managers, Auditors, Compliance Officers


Brian Crow

Brian Crow, CAMS is Managing Partner & Co-President at Thomas Compliance Associates, Inc. in Chicago, IL. Brian’s passion for and skill in protecting bank assets from fraud and compliance losses have earned him the nickname “Security Evangelist.” In addition to developing and guiding the strategic vision for TCA, Brian delivers focused educational support to clients and helps them manage TCA’s suite of consulting, audit, and training services. He is a nationally recognized expert on BSA/AML and deposit compliance and is a regular speaker at the annual BSA/AML Top Gun Conference. As an education consultant for the Glia Group BOL Learning Connect program, Brian conducts webinars on topics like VISA/MasterCard chargebacks, debit card compliance, and fraud prevention. For this work, he was recognized as a Bankers Online Guru in 2011. “Bach to Spock” could characterize his interests outside work. Music has been a lifelong passion, and Brian is the organist and handbell director for King of Glory Lutheran Church in Elgin, Illinois. And as a devoted Trekkie, he can hold my own with anyone in a Star Trek trivia match.

Course curriculum

  • 1


    • Automated Monitoring Systems: Implementation to Validation

  • 2


    • Slides

    • FDIC Model Covernance

    • Model Risk Managmeent Program Policy Template

    • Release Update Review

    • Model Usage Policy Board Level

    • OCC Model Validation

    • Questions and Answers