FIBA Correspondent Banking AML Course
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| The risks posed by correspondent banking are of concern to regulators, bankers, and broker-dealers in securities alike. Recently, U.S. financial institutions have faced severe penalties as a result of having weak AML/BSA compliance programs for their foreign correspondent banking accounts. The various sections of the USA PATRIOT Act and implementing regulations in the Bank Secrecy Act have been in final form for a number of years now. This course will discuss not so much the regulations but rather the practical applications of the regulatory requirements, with a particular emphasis on nested accounts |
•Internet Gambling and Correspondent Banking
• Name Screening
- Section 311 – Special Measures - Bureau of Industry Standards (export control) - Office of Foreign Assets Control - Consequences of Sanctions Non-Compliance : Lessons Learned - Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 • Correspondent Banking BSA/AML and OFAC Contract Considerations
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• Brief History and Regulatory Expectations
• Definition of Correspondent Banking with a mention of foreign MSBs
• Foreign Financial Institution Risk Rating Methodology
- In depth discussion of items to consider for each risk factor • Due Diligence Program
- General Due Diligence Considerations - Discussion of Nested Accounts and the Informal Value Transfer System and Offshore Intermediaries - Enhanced Due Diligence Considerations - On-Going Due Diligence Requirements - Certifications - Access to Records • Transaction Monitoring Program
- Program Requirements with a Focus on the Review the following Transaction Types and the associated Red Flags: Wire Transfers, International ACH, Bulk Cash, Cash Letter/Pouch, Remote Deposit Capture, Dollar Drafts, Trade Finance • Case Studies
- Detailed Review of Enforcement Actions for Lessons Learned |
It is recommended that (i) the Case Study materials be studied and reviewed and (ii) the items noted as “Required Reading” be reviewed before the class. Since a significant amount of time is taken on the cases, there is the possibility that not all the cases will be reviewed during the course if time was not taken before the course to read the case studies in depth. Reading time is estimated at 5-7 hours.
Participants will be required to successfully complete an exam immediately following the training. Participants will receive a certificate of completion after passing the test. Approved for 7 continuing education credits for professional who have earned their FIBA AMLCA or FIBA CPAML Certification. |
