The USA PATRIOT Act, Section 352, describes the requirements for a BSA/AML/OFAC Program. The Fourth Pillar of an effective program is the training of all staff with BSA responsibilities. As BSA Programs have evolved, financial institutions have determined that the best way to fulfill the requirement is to train all staff in the fundamentals of the Bank Secrecy Act and Anti-Money Laundering, as well as the Office of Foreign Exchange (OFAC), so that the staff has the proper understanding to recognize – and report internally – suspicious activities.
Why Should You Attend:
This course covers all important aspects of BSA/AML/OFAC to satisfy the annual training requirement. It provides a basic understanding of the elements of the Bank Secrecy Act and the increased monitoring required by the various sections of the USA PATRIOT Act. As the FFIEC Manual states, “Banks must ensure that appropriate personnel are trained in applicable aspects of the BSA. Training should include regulatory requirements and the bank’s internal BSA/AML policies, procedures, and processes. At a minimum, the bank’s training program must provide training for all personnel whose duties require knowledge of the BSA. The training should be tailored to the person’s specific responsibilities. In addition, an overview of the BSA/AML requirements typically should be given to new staff during employee orientation.” This training will also fit into the training for Senior Management.
– Money Laundering and How it Occurs
– The Bank Secrecy Act and its Development
– The USA PATRIOT Act
– Customer Due Diligence
– Beneficial Ownership
– Office of Foreign Assets Control
– Important International AML Agencies
Areas Covered in the Course:
– Bank Secrecy Act and Money Laundering Laws
– USA PATRIOT Act, Title III, “International Money Laundering and Anti-Terrorism Abatement Act
– Customer Due Diligence
– Suspicious Activity Reporting
– Office of Foreign Assets Control and Sanctions
– Penalties for Failure to Adhere
Who Will Benefit:
– Chief Compliance Officers
– BSA Officers & Analysts
– General Staff
– New Hires
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.