Preparing for a BSA/OFAC Regulatory Examination
Thomas E Nollner has more than 38 years of experience in financial institution supervision and consulting. Mr. Nollner spent 30 years as a National Bank Examiner (NBE) for the Comptroller of the Currency where he was a safety and soundness examiner and a compliance examiner. The last 15 years as an NBA and for the past 8 years as a consultant, Mr. Nollner has specialized as an AML/CFT examiner/consultant. In these roles he has analyzed financial institutions’ AML/CFT programs to ensure that they complied with applicable AML/CFT laws, rules, and regulations; he reviewed the suspicious transactions identification, monitoring, and reporting processes; he traced proceeds and transactions through several layers of activity; and he provided AML/CFT training for many different financial institutions.
Mr. Nollner currently works as a consultant for the Office of Technical Assistance (OTA), a branch of the US Treasury that assists developing countries with banking issues. Mr. Nollner is assigned to the Economic Crimes Team that focused on training, assisting, and mentoring the staffs of the financial regulatory departments and financial intelligence units of various countries regarding AML/CFT compliance. In this capacity, he worked in countries such as Afghanistan, Iraq, Turkmenistan, Viet Nam, Honduras, Guatemala, Guyana, Suriname, and Argentina developing AML/CFT examination procedures, providing AML/CFT training and mentoring, and updating local AML/CFT laws and regulations.
The BSA examination process is intended to assess the effectiveness of a financial institution’s BSA compliance program and the institution’s compliance with the regulatory requirements related to the BSA. A regulatory examination should cover a review of the risk management process, an analysis of the institution’s independent testing system, a detailed and thorough of the BSA compliance program, transaction testing where appropriate, a specific review of the suspicious activity identification, monitoring, and reporting systems, and a review of IT systems used in the BSA process. This webinar will discuss ways you can prepare for the regulatory examination by reviewing your previous examination or audit reports, available work-papers related to the examinations, and management’s responses to identified BSA issues. You will also want to review any correspondence between your institution and its regulators, law enforcement agencies related to BSA compliance, FinCEN, and the IRS. You should also review prior to the examination, all of your IT systems and processes, all of the reports you are required to provide to regulators, your processes for complying with Office of Foreign Assets Controls (OFAC), and especially ensure that your Suspicious Activity Reporting processes and Currency Transaction Reporting processes fully comply with all laws and requirements.
Almost every financial institution is supervised by a government regulatory agency. An important part of this supervision process is a regulatory examination conducted by the government agency to ensure that the financial institution is compliant with appropriate laws and regulations.
Preparing for the Examination to include:
- Assigning a point of contact
- Gathering needed information
- Assigning appropriate staff
- Reviewing previous examinations
- Reviewing previous audits
- Gathering all written policies, procedures, and desk practices
- Ensuring Senior management support to be cooperative with regulators
Course Level - Intermediate. This webinar will target the entire examination process and address all areas of a financial institution’s operations from the most basic/fundamental processes to the most advanced processes that the institution conducts. As such, this webinar will discuss issues involving employees with a fundamental understanding of the institution's operations to senior managers and directors of the institution who have advanced knowledge of operations.
Who Should Attend
- Directors of the Institution
- Managers of the Institution
- Risk Managers
- BSA Officers
- Compliance Officers
- Audit Staff
- BSA Staff
Why Should You Attend
This webinar will discuss how your financial institution should prepare for a BSA regulatory examination. We will address the requirement, need, and importance of an examination, how you can use the results of an examination to improve your organization's operations, how to assign responsibilities for your staff, and how to the phases of the examination. Attending this webinar will help you understand that examinations are a normal part of the regulatory process and are no different than an internal or external audit. All of these reviews, examinations, and audits provide your institution with a third-party review of your operations, provide you with suggestions of how to improve your operations, and point out your level of compliance with AML/CFT laws and regulations. The examination process should not be thought of as a negative event, but as a positive process for your institution to find out how compliant the organization is, help you identify areas that need to be improved, and provide you with expert knowledge of industry standards currently used by other financial institutions. Regulatory examinations and audits are a requirement that will always be a part of the supervision process for all financial institutions and as such should be accepted and used to improve your business operations.