Ten Points Regulators Will Be Looking For On Your …content.aba.com/briefings/3014675.pdfAmerican Bankers Association Ten Points Regulators Will Be Looking For On Your Next AML Exam

ABA BRIEFING | PARTICIPANT’S GUIDE

Ten Points Regulators Will Be Looking For

On Your Next AML Exam

Tuesday, September 20, 2016 Eastern Time

2:00 p.m.–3:30 p.m. Central Time

1:00 p.m.–2:30 p.m. Mountain Time

12:00 p.m.–1:30p.m. Pacific Time

11:00 a.m.–12:30 p.m.

American Bankers Association Ten Points Regulators Will Be Looking For On Your Next AML Exam Tuesday, September 20, 2016 2:00 – 3:30 p.m. ET

DISCLAIMER This Briefing/Webcast will be recorded with permission and is furnished for informational use only. Neither the speakers, contributors nor ABA is engaged in rendering legal nor other expert professional services, for which outside competent professionals should be sought. All statements and opinions contained herein are the sole opinion of the speakers and subject to change without notice. Receipt of this information constitutes your acceptance of these terms and conditions.

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Table of Contents

TABLE OF CONTENTS ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II

SPEAKER & ABA STAFF LISTING ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III

SPEAKER BIOGRAPHIES ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV

PROGRAM OUTLINE ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V

CONTINUING EDUCATION CREDITS INFORMATION ... . . . . . . . . . . . . . . . . . . . . . . . . VI

CPA SIGN-IN/SIGN-OUT SHEET ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . VII

INSTRUCTIONS FOR RECEIVING CERTIFICATES OF ATTENDANCE .. VIII

PROGRAM INFORMATION ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ENCLOSED

PLEASE READ ALL ENCLOSED MATERIAL PRIOR TO BRIEFING. THANK YOU.

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III

Speakers and ABA Staff Listing

Speaker and Moderator Gary Lindsey Principal Crowe Horwath LLP One Columbus Columbus, OH 43215 (614) 280-5281 [email protected] Speakers John Epperson Principal Crowe Horwath LLP 225 West Wacker Chicago, IL 60606 (630) 575-4220 [email protected]

ABA Briefings Staff Cari Hearn Senior Manager (202) 663-5393 [email protected] Linda M. Shepard Senior Manager (202) 663-5499 [email protected]

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IV

Speaker Biographies

GARY LINDSEY Gary is the National Practice Leader for BSA/ AML Audit Services as part of Crowe Horwath LLP’s overall Risk Practice, with more than 17 years of experience leading BSA/AML audits and reviews. In this role Gary is responsible for the oversight and maintenance of service standards, staff development, quality assurance and technical standards for approximately 150 BSA/ AML recurring audits conducted by the Firm each year. Gary is also responsible for the direct oversight and performance of BSA/AML audits for the Firm’s largest and most complex bank and non-bank financial institutions and serves as a trusted advisor to their Board of Directors and Audit Committees. JOHN EPPERSON John is a principal with Crowe Horwath LLP specializing in the areas of financial institution risk management, model risk management (MRM), auditing/internal controls, and Anti-Money Laundering (AML) regulatory compliance. John leads Crowe’s Payments regulatory compliance practice and maintains a leadership role within the firm’s national AML and MRM practices. John is responsible for designing and executing regulatory compliance audit and system validation testing plans, implementing and enhancing enterprise wide compliance programs for bank and non-bank financial service companies and a trusted advisor in leading projects that have withstood examination in some of the most intense regulatory environments in recent history.


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PROGRAM OUTLINE TIMES SESSION AND SPEAKERS

1:45 – 2:00 p.m. ET Pre-Seminar Countdown

2:00 – 2:02 p.m. Welcome and Program Introduction

1Source International

2:02 – 2:10 p.m. Opening Comments and Speaker Introductions Program Agenda and Background

Gary Lindsey, Crowe Horwath LLP

2:10 – 2:25 p.m. Segment 1 Exploring recent trends in AML supervision

Discussing areas of intensified regulatory scrutiny

John Epperson, Crowe Horwath LLP Gary Lindsey, Crowe Horwath LLP

2:25 – 2:45 p.m. Segment 2 Identifying practical approaches for meeting regulatory expectations Discussing operational impact of new regulatory guidance


2:45 – 2:50 p.m. Questions & Answers

2:50 – 3:20 p.m. Segment 3 Practical tips for your next AML Exam


3:20 – 3:30 p.m. Questions & Answers Wrap-up


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Continuing Education Credits Information

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CPA Required Sign-in/Sign-out Sheet

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VIII

Instructions for Receiving Certificates of Attendance

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aba.com 1-800-BANKERS

Ten Points RegulatorsWill Be Looking For on Your

Next AML Exam

ABA Briefing/WebinarTuesday, September 20, 2016


Disclaimer

This Briefing will be recorded with permission and isfurnished for informational use only. Neither the speakers,contributors nor ABA is engaged in rendering legal norother expert professional services, for which outsidecompetent professionals should be sought.

All statements and opinions contained herein are the soleopinion of the speakers and subject to change withoutnotice. Receipt of this information constitutes youracceptance of these terms and conditions.

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With You Today

John Epperson, Principal

Crowe Horwath LLP

Diversified Payment / Fintech Practice Leader

AML Model Risk Management

FS Regulatory Compliance Consulting /Audit

Gary Lindsey, Principal

Crowe Horwath LLP

Global AML Audit Practice Leader

AML Regulatory Order Response

FS Regulatory Compliance Consulting /Audit

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Learning Objectives

Exploring recent trends in AML supervision

Discussing areas of intensified regulatory scrutiny

Identifying practical approaches for meeting regulatory expectations

Discussing operational impact of new regulatory guidance

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AML Regulatory Landscape

• Regulatory supervision and focus on AML compliance programs remains high

• Many are reporting continued or increased examiner presence as it relates to AML supervision

• Continued headlines, public actions, fines, and penalties

• Heighted expectations increasingly seen at smaller organizations

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©2016 Crowe Horwath LLP 66

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Point #1: Past Observations and Recommendations

Question: Have you remediated all past issues/ findings?


Past Observations/ Recommendations

The most common exam planning points

Past observations and recommendations can derive from several sources:– Report of Examination– Supervisory Letter– Consent Order/ Formal Agreement– Internal Audit Reports– Self‐Testing Reports

Examiners focus on understanding how issues have been resolved, including the sustainability of the controls

View point that past observations/ recommendations are not “closed”/ “remediated” until adequately tested or validated by Internal Audit

Important to have well documented plans and strategy for longer‐term corrective action project

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Past Observations/ Recommendations

How to Prepare for Your Next Exam

Inventory all open Internal Audit, Self‐Testing, and Regulatory observations/ recommendations

Ensure remediation efforts are complete and well‐documented in terms of resolution

For remediation activities that are still ongoing, ensure that appropriate documentation is retained to support remediation progress

Ensure the organization’s testing program has tested remediation efforts and concluded on their achievement/ success

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Point #2: Changes in Risk Profile

Question: Have you experienced a significant event that has caused a change in your AML risk profile?

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Changes in Risk Profile

There is a continued emphasis from Regulators on an organization’s ability to identify and respond to changes in their AML risk profile.

Failure to understand AML risk associated with new products, services, and customer segments is an underlying theme of most enforcement actions

Examiners are focusing not just on the identification and response to changes in AML risk, but how timely the organization is able to both identify and respond to these changes.

Measuring, analyzing, and responding to risks through the annual risk assessment process presents challenges and does not meet Regulator’s increased expectations.

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Changes in an organization’s AML risk profile may occur periodically and may be the result of both internal and external events. Examples include:

– Implementation of new software or technology;– Turnover or changes in staff;– Introduction of new products or services; – Geographic expansion; – Acquisitions or combinations;– Growth in high risk product or customer segments; and– Changes in geographic risk.

An effective response to changes starts with a comprehensive and transparent assessment of risk, not just an exercise of compliance

The identification of changes, and their assessment of risk, should effectively allow for the flow of resources, investment, and infrastructure to manage the change in risk to the organization.

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Revisit how your organization identifies events or changes in risk.• Do you have effective process for timely, or proactive, identification of risk

changes?

Understand any significant changes or events that have occurred since your prior examination.

Ensure the risks associated with any changes or events have been assessed and well‐documented.

Evaluate the sustainability of any controls implemented as a result of AML risk profile changes.


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Point #3: AML Systems and Tools

Question: Are your systems prepared to meet the growing complexity of AML processes and growing regulatory expectations?

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AML Systems

AML systems are increasingly the cornerstone of an effective AML program

The failure of systems relied upon for AML compliance is the leading factor associated with fines, penalties, and enforcement actions

Examples of AML systems include transaction monitoring, customer risk rating, and sanctions list screening

The dynamics and sophistication of AML systems have advanced significantly over the last several years

Strong system/model governance overseeing aspects of system development/implementation, validation, and ongoing use.

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AML System Risks

Risk Risk Example

Design and Development RiskThe system is not aligned to identify typologies of money laundering and financial crime consistent with products, services, and geographies

Implementation Risk System is incorrectly configured to account for relevant business and regulatory requirements

Input Processing Risk System data is inaccurate, incomplete, or stale

Performance Risk Product or customer risks change overtime with adjustments not properly applied to the system

Output and Use Poor business decisions are applied to the system output

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System/Model Risk Management

Have we identified all of our AML models?

Did we implement the model correctly and do we have documentation to prove it?

Have we independently validated that the model is performing as intended?

Are we calibrating the model thresholds and parameters overtime?

Do we have the right system controls to ensure the performance of the model overtime?

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AML Systems

Ensure you have inventoried and identified all the systems and models used to support the organization’s AML compliance program

Ensure system or model output is up‐to‐date and free of back‐logs

Verify that supporting systems and models have been tested and/ or validated

Ensure AML system and model governance controls are aligned to bank‐wide governance policies

Ensure that past findings from model validations or system testing have been fully remediated


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Point #4: Independent Testing

Question: Does your internal audit staff have the capabilities required to effectively assess AML compliance?


AML Independent Testing

AML/BSA and Sanctions audit is the most frequently cited violation

Evaluated by Regulators during the exam planning, but also throughout the exam

Examiners are increasingly leveraging audit results and workpapers to shape an examination

Expanding AML qualifications are needed to satisfy increasing regulatory demands

Increased focus on the depth, quality, and coverage of testing performed

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Auditors are increasingly challenged to audit to not just to regulations, but also to examiner expectations– Including credible challenge to established policies, procedures, and controls

Increased attention to audit’s ability to audit changes in risk, remediation of past issues, and new regulations and guidance

Regulatory view point that past regulatory and audit issues remain open until effectively tested or validated

The most successful organizations look to AML audit as an opportunity to flush out and address issues prior to an examination

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Ensure you have the right mix of both AML and internal audit professionals completing audit activities

• Includes both internal and external resources

Determine if the remediation of any past regulatory exam or audit issues have been successfully tested/ validated by internal audit

Verify that internal audit personnel are informed of significant changes in your AML risk profile

Verify that significant changes in your AML risk profile have been tested or evaluated by internal audit

• Includes new products and services, acquisitions, combinations, etc.


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Point #5: AML Resources/ Staffing

Question: Does your bank have a plan in place to help leaders address and resolve AML risks?


AML Resources and Staffing

AML professional expertise is in significant demand

The depth and quality of AML resources is a significant exam evaluation point

Increased focus on AML professionals ability to effect change and influence

Examiners are looking for indicators of insufficient resources during the examinations• Past due reporting, backlogs, slow response to change, etc

Increased regulatory focus on reporting channels and communication lines• Sufficient access to board and be sufficiently empowered to be effective and

have sufficient, competent resources

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AML Resources and Staffing

Increased regulatory focus on the resources supporting the compliance program, not just staffing

– Includes enabling technology, tools, and systems supporting the compliance program

The degree and complexity of needed resources may increase as an organization’s risk profile changes

Examiner focused on understanding that the right level of technology and tools are maintained commensurate with an organization’s risk profile

‐ Examples may include transaction monitoring systems, customer risk scoring systems, case management platforms, etc

Enabling technology and tools should align with an organization’s current business and regulatory needs, as well as align to the strategic direction of the organization

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AML Resources/Staffing

Verify that resumes and CVs for AML professionals are up to date and current

Perform capacity assessment or employ use of capacity model to monitor resource needs

Document resource or capacity plans for areas of significant turnover

Establish documented plans to remediate compliance requirements outside of established procedural timeframes or Service Level Agreements (SLAs)

Evaluate if defined business needs are able to met through existing tools, resources and systems

Evaluate if existing tools and resources are in‐line with strategic direction of the organization


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Point #6: Transaction Monitoring Processes

Question: Are your transaction monitoring processes effective in identifying suspicious activity?


Transaction Monitoring Performance

Enhanced monitoring of third party risks (correspondent banking, payment processing, TPPP)

Focus on monitoring all risks which may be more than just customers (e.g. customer’s customer, device)

More information and insight on SAR decision making

Knowing when a model is not performing as expected

Advancements in machine learning, cognitive learning, and advanced analytical monitoring

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Tuning and Optimization

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Tuning and Optimization

Triggering Events

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Transaction Monitoring Performance

Map relevant AML typologies to transaction monitoring coverage whether that be automated, manual, or LOB control

Ensure the maintenance of prescriptive and statistically valid tuning and optimization methodology and processes

Maintain documentation to demonstrate empirical evidence that your thresholds and parameters are appropriate

How and when are you going to tune and optimize thresholds overtime (e.g. event based metrics and measures to support performance monitoring overtimes)

Demonstrate effective segregation of duties throughout tuning processes


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Point #7: Third Party AML Risks

Question: How are you managing Third party AML risks that might exist at your organization?

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Third Party AML Risks

Increased industry reliance on third parties for management of certain BSA/AML functions

Fintech and digital disruption resulting in new and emerging riks

‐ Bank partnerships

‐ Bank account reliance

Increasing compliance risks on not just flow of funds, but the flow of information

Reliance on vendor systems and algorithms

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Third Party AML Risks

Strong documented oversight and testing of effectiveness of controls when relied upon by third party

Define roles, responsibilities, resources when partnering with non‐bank financial institution

Demonstrate due diligence on marketing and sales methods when engaged with TPPP

Assess risks that exist with not just the flow of funds but the retention of transactional information

Maintain documentation to support “black box” vendor supported systems


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Point #8: High Risk Customer Administration

Question: Are you effectively identifying and mitigating high risk customers?


High Risk Customer Administration

Movement toward creative uses of alternative data or tech‐enabled KYC

Beneficial Ownership ruling impact

Maintenance of relevant KYC/CDD information overtime

Reliance on Third Party CDD/CIP/KYC

Continued focus on EDD documentation standards

Tuning and validation of customer risk scoring models

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High Risk Customer Administration

Justification of tech‐enabled EDD or reliance on third parties

Ensure your EDD processes are tailored to specifically address the unique risk factors presented by varying customer types

Retain documentation to support and justify reasonableness of customer risk scoring model and its overt linkage to your risk assessment

Define risk based collection of beneficial ownership, roadmap to compliance with beneficial ownership ruling

Strong processes and quality assurance supporting adherence to EDD documentation standards and timeliness


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Point #9: Single Customer View

Question: Are you able to monitor and assess AML risks through a single customer view?

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Single Customer View

Siloed and legacy banking systems and lines of business impact ability to assess and monitor enterprise AML risk

Beneficial Ownership ruling impact

Integration of single customer view into AML system (e.g. monitoring and customer risk rating)

Concerns in leveraging third parties to support aspects of CDD/CIP/KYC

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Single Customer View

Identify risks and corresponding controls to consolidate key KYC/CDD information to conclude on consolidated risk of customer

Define any applicable technology roadmap that seeks to consolidate and streamline a single customer view

Be prepared to discuss tactical and strategically means to comply with beneficial ownership ruling ‐ better to vet now than in two years from now

Assess linkage of shared relationships across the enterprise (e.g. customer residing in multiple businesses or services


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Point #10: Sanctions Program

Question: Are you able to monitor and assess AML risks through a single customer view?


Sanctions Program

Significant gaps, oversights, and intention circumvention of global sanctions compliance has raised the bar for all financial institutions

Clear focus on Sanctions compliance system integrity, performance, and management controls

Increasing focus on third party sanction risks

New methods and means in targeting sanctioned entities

Evaluation and documented acceptance of any risks

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Sanctions Programs

Adherence to system/model risk management practices

Strong knowledge as to how the screening system conduct the screenings and it’s sensitivity to name variations

Test, tune, and optimize sanctions screening tools to ensure they appropriately mitigate changes in exposure

Clearly identify the type and quality of the data being screened, source of the data inputs, and understanding of the elements included in the lists.

Clear audit trail to support evidence of sanctions screening (including third parties) and documentation to support clearing potential listed names


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Questions and Answers

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and Press ENTER / SUBMIT.

If you are participating by Phone:Email your Question to: [email protected]

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In accordance with applicable professional standards, some firm services may not be available to attest clients.

This material is for informational purposes only and should not be construed as financial or legal advice. Please seek guidance specific to your organization from qualified advisers in your jurisdiction.

© 2016 Crowe Horwath LLP, an independent member of Crowe Horwath International crowehorwath.com/disclosure

John Epperson, PrincipalPhone +1 630 575 [email protected]

Thank you

Gary Lindsey, PrincipalPhone +1 614 280 5281 [email protected]

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Documents

Ten Points Regulators Will Be Looking For On Your …content.aba.com/briefings/3014675.pdfAmerican Bankers Association Ten Points Regulators Will Be Looking For On Your Next AML Exam