2022 BSA/AML Top Gun Conference

Despite all the challenges that 2021 presented for us, the 2021 Top Gun Conference proved to be a huge success with more participants than any other that I have attended. The virtual format provided a wonderful opportunity to train multiple employees on relevant topics without costly travel or disruption to daily routines. Recorded sessions allowed you to spend time training when it was convenient for you and to share relevant sessions with other departments. BOL Conferences heard you loud and clear, so we are going to provide the same convenient remote option for Top Gun 2022!

BSA is constantly evolving, and this past year was no exception. With the passage of the Anti-Money Laundering Act (AMLA) in December 2020, FinCEN has its work cut out for it with putting together new studies, new priorities, and new regulations. Our team of expert speakers is closely monitoring these developments so that we bring you the most current information you need to know for your BSA Program. Additionally, Top Gun continues to be your best resource for the practical application of BSA requirements whether you are developing a training program, completing Suspicious Activity Reports, or trying to stay current with the hot topics and changing rules.

Top Gun provides the relevant information you need in easy-to-understand discussions. One of the impacts of an increase in remote banking due to COVID has been an increase in cyber related fraud and online scams. However, many BSA Officers may not be well versed in “tech” language which complicates the SAR decision making process. This year we are going to cut through the “technobabble” and provide guidance on how to evaluate what constitutes a cyber event and what steps you need to take.

Feedback from previous conferences indicates that our question-and-answer sessions continue to be some of the most popular time during the conference. Have a question? Ask it! There is a good chance that one of your fellow participants has the same question. Have a topic suggestion? Submit it to [email protected]. This is your conference, and we want to provide relevant topics to support your BSA Program.

I would like to personally invite you to join me and our expert speaker panel on March 8th and 9th for Top Gun 2022.

I look forward to “seeing” all of you on March 8th and 9th.

Warm regards,
Brian Crow
BOL Conferences Coordinator

P.S. Register early!

SAR Completion – Deborah Crawford
Here a checkbox, there a checkbox, everywhere a checkbox! The Suspicious Activity Report is one of the most complex documents we must complete. Nuances abound in the various types of suspicious activity we are expected to report, and the types of products and instruments involved in the suspicious activity. In this session we will walk you through the report line by line to help you make sure nothing gets missed when you are filing your reports.

What Happened Since Last Year? – Brian Crow
It was another busy year for FinCEN due to the passage of the Anti-Money Laundering Act in December 2020 and another year of growing electronic crime due to the continuation of COVID. We’ll bring you up to speed on current happenings in the Bank Secrecy Act, recent enforcement actions, and changes that may be on the horizon.

De-risking customers – Deborah Crawford
When evaluating customer risk, compliance risk, financial risk, and legal risk are often the first that come to mind. However, reputation risk is quickly catching up. The decision to provide banking services to a particular individual or industry could be impacted by a desire to avoid affiliation with “social hot buttons” such as cannabis or adult entertainment. In this session we will discuss how to evaluate and document our risk tolerances and what steps we should take to mitigate risk.

Building a Training Program – Deborah Crawford
Many institutions take a “checkbox” approach to BSA training. Assign everyone an online BSA course and we’re good for another year, right? The regulatory requirements are that each employee receive job specific BSA training that includes general BSA knowledge and institution specific policy and procedures. Simply checking a box does not address this requirement. In this session we will cover the steps you should consider to build a comprehensive training program for new and current employees, the BSA Department and your board to ensure everyone has the knowledge they need for a successful BSA Program.

Suspicious Activity Priorities and Red Flag Monitoring (Parts I and II) – Victor Cardona
One of the requirements of the Anti-Money Laundering Act was for FinCEN to publish AML priorities to highlight the types of crimes it sees as presenting the greatest risk to the United States. FinCEN published a list of eight priorities on June 30, 2021. They include corruption, cybercrime, terrorist financing, fraud, transnational criminal organization activity, drug trafficking organization activity, human trafficking and human smuggling, and proliferation financing. While this publication did not create any new rules for our BSA Programs, we should be mindful of these types of activities should they occur through our institution. In this two-part session, we will cover four of the eight priorities in each and discuss red flags you should consider in your monitoring to determine if this activity is taking place.

Insider Abuse Monitoring and Reporting – Robin Guthridge
One of the most delicate types of investigations we must conduct is in suspected cases of insider abuse. On one hand we want to protect the institution and its customers from loss and on the other, not tip off the insider that we suspect something is wrong until we complete our investigation. Matters can be further complicated if the insider is a board member or high-level executive who would normally receive updates of SARs. This session will provide suggestions and processes for managing internal investigations and SAR reporting.

What Qualifies as a Cyber Event? – Brian Crow
Cyber Events are one of FinCEN’s eight AML Priorities. However, many BSA Professionals have limited IT backgrounds and struggle to know when a Cyber Event SAR is needed or how to complete one. In this session, we will consider FinCEN’s cyber event guidance and explore several scenarios to help you understand when SARs are required and how they should be completed. We’ll also define some of the more complex cyber lingo to help guide you along the way.

Banking the Cannabis Industry – Robin Guthridge
As prevalent as the cannabis industry has become in states where it is legal in some form, it is likely not a matter of “if” you’re banking it, but “how much” and “do you know” that you are banking it. In absence of any guidance since 2014 on marijuana and 2020 on hemp, cannabis continues to present risk and treacherous terrain for the financial industry. In this session we will cover the status of federal legislation and best practices for due diligence and ongoing monitoring.