| Louisville, KY

BSA School

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Tuesday, August 15

Sessions start at 8:30 a.m. ET and end at 4:00 p.m. ET
  • 7:00 a.m. - 8:30 a.m.
    Networking Breakfast
  • Welcome Address
  • The ABC's of the Bank Secrecy Act (BSA)

    History and background of the BSA:

    - 9/11 and the USA PATRIOT Act

    - What part government agencies play concerning the BSA

    - Understanding money laundering and terrorist financing

    - Why BSA matters for financial institutions of all sizes

  • Networking Lunch
  • BSA's Five Pillars

    Learn what an effective BSA/AML compliance program includes:

    - Written policies and procedures

    - A designated BSA officer

    - Independent testing

    - Adequate employee training

    - Risk-based, customer due diligence

  • BSA/AML Compliance Program/Risk Assessment

    Identify specific risk categories: ­

    - Products and services ­

    - Member/customers and entities

    ­- Geographic locations ­- Analysis of specific risk categories

    ­- Developing the BSA/AML compliance program based upon the risk assessment ­

    - Updating the risk assessment

  • Member/Customer Identification Program (CIP)

    - What is an account

    -What information must be obtained when opening an account

    -Verifying a member’s identity

    - Recordkeeping and retention requirements

    - Adequate notice

    - Internal controls

  • Member/Customer Due Diligence (CDD)

    - Establishment of risk-based policies, procedures and processes in relation to a credit union’s BSA/AML risk profile

    - Understanding the nature and purpose of the member relationship in order to develop a risk profile

    - Obtaining member information to substantiate the nature and purpose of the account

    - Use of risk-basis procedures to maintain and update customer information

    - Conduct ongoing monitoring

    - Higher risk profile members and enhanced due diligence

  • Wrap Up
  • 5:00 p.m. - 6:30 p.m.
    Welcome Reception

Wednesday, August 16

Sessions start at 8:30 a.m. ET and end at 4:00 p.m. ET
  • 7:00 a.m. - 8:30 a.m.
    Networking Breakfast
  • Welcome/Recap
  • Beneficial Ownership Requirements for Legal Entity Member/Customers

    - Beneficial Ownership rule requirements
    - What is a legal entity
    - What is a beneficial owner
    - Identification and verification of beneficial owners
    - Recordkeeping and retention requirements
    - Reliance on another financial institution

  • Suspicious Activity Reports (SARs)

    - Monitoring, detecting and reporting suspicious activities
    - Regulatory requirements to file a SAR
    - Safe harbor from civil liability
    - Systems to identify, research and report suspicious activity
    - Identifying unusual or suspicious activity
    - Managing alerts
    - SAR decision making

  • Networking Lunch
  • Currency Transaction Reports (CTRs) - Part I

    - Reporting large currency transactions
    - Identity verification requirement
    - Aggregating currency transactions
    - Structured transactions – CTR requirements
    - Filing CTRs and record retention
    - Shared branches
    - Back filing

  • Currency Transaction Reports - Part II Reporting Exemptions

    - Phase I CTR exemptions
    - Phase II CTR exemptions
    - Annual review
    - Operating rules
    - Safe harbor for failing to file
    - Effect on other SAR filings or other regulatory requirements

  • Wrap Up & Exam Expectations

Thursday, August 17

Sessions start at 8:30 a.m. ET and end at 12:00 p.m. ET | *Note: An optional exam for credentialing will follow the close of sessions on Thursday.
  • 7:00 a.m. - 8:30 a.m.
    Networking Breakfast
  • Welcome/Recap
  • Information Sharing

    - Section 314 of the USA PATRIOT Act information requests
    - Information sharing between law enforcement and financial institutions – (section 314(a) of 31 CFR 1010.520)
    - Voluntary information sharing – (section 314(b) of 31 CFR 1010.540)
    - SAR supporting information 

  • Office of Foreign Assets Control (OFAC)

    - What is OFAC (history and background)

    - Blocked and prohibited transactions

    - OFAC licenses

    - Reporting

    - Compliance program     

              - A Framework for OFAC Compliance Commitments

    - Internal controls

    - Independent testing

    - Designated responsible individual

    - Training

  • Networking Lunch
  • Recordkeeping

    - Purchase and sale of monetary instruments recordkeeping

          - Recording of information required for the purchase and sale of monetary instruments for currency in amounts between $3,000 and $10,000

    - Funds transfers recordkeeping

          - Originator financial institution responsibilities

          - Beneficiary financial institution responsibilities

          - Money laundering risks for funds transfer activities

    - BSA record retention requirements

  • Wrap Up & Exam Prep
  • NCBSO Exam