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Course description

BSA is one of the few regulations where compliance is so critical that it is classified as a “safety and soundness” issue.  BSA failures lead to substantial civil money penalties, criminal prosecution, and the potential loss of a financial institution’s charter. The United States is clearly part of a global economy that presents unique risks for money-laundering and international crimes and terrorist threats. Thirty states in the US have some version of legalized marijuana – either recreational, medicinal or both. This means banking marijuana-related businesses continues to be an ongoing risk decision for bankers. What are the expectations of YOUR regulator for BSA and AML compliance in 2019? The OCC (Office of the Comptroller of the Currency) announced that BSA compliance is another key risk in 2019.  Specifically, the OCC said it will focus on “determining whether AML compliance programs keep pace with changing risk environments and regulatory developments.”  All prudential regulators have a strong focus on BSA compliance, as criminal activity becomes more sophisticated and cybersecurity risks increase.

What you will learn in this session about BSA Special Risks in 2019:

  • Enforcement actions – failure to implement risk-driven compliance, untimely SAR filings, inaccurate CTRs and more.
  • CDD and Beneficial Owners -are you prepared for the next exam?
  • Monitoring for High-Risk Activities – identification and risk mitigation steps
  • SARS and detecting red flags – new fields include “cyber events” and additional products and subtypes. Best practices for effective monitoring.
  •  Inadequate testing and monitoring systems - learn about regulators’ expectations for automated and manual approaches
  • Banking Money Services Businesses – Unique challenges
  • “Hot Issues” 
  • Marijuana Banking- FinCEN related guidance and developing a policy
  • Cybersecurity threats and fraud risks – FinCEN guidance and detection
  • Elder Financial Exploitation (EFE) – Tips for detection and SAR requirements
  • Privately-owned ATMs – important definitions, Independent Sales Organization relationships and best practices
  • Crypto currency – FinCEN guidance and special issues

Who Should Attend: This informative session is designed for anyone with BSA/AML responsibility, especially designated BSA Officers and staff, Senior Management, security/risk managers, Compliance Officers, Auditors, legal counsel, and training staff.


Susan Costonis

Course curriculum

  • 1


    • Is your BSA and AML program at RISK?

  • 2


    • Slides

    • Materials

    • Questions and Answers

    • Attendance Sheet