This course will review and discuss recent Enforcement Actions issued by the Office of the Comptroller of the Currency and FinCEN to help participants understand the process used by regulators and law enforcement when developing and issuing Enforcement Actions. The session will include Enforcement Actions for banks and money service businesses. We will review the regulatory history and background of the financial institution involved, the findings of the regulators and law enforcement during examinations and onsite reviews, the reasoning behind the Enforcement Actions, and the expectation of the regulators and law enforcement going forward. In addition, we will discuss policy changes, procedure enhancements, and operational practices the financial institution could have taken to prevent the weaknesses that caused the Enforcement Action
why one should attend the training
You should attend this webinar because reviewing and analyzing the issues and violations of law identified in Enforcement Actions by regulators and law enforcement can help you understand, mitigate, and hopefully prevent the same types of problems in your AML program. The more aware you are of the focus regulators and law enforcement place on certain areas of bank operations, the better you can ensure that your institution has policies and procedures in place to fully compliance with all laws and regulations.
objectives of the Topic
- Understanding the Enforcement Action Process
- Obtaining an Awareness of Laws and Regulations related to the Enforcement Action Process
- Learning the Dollar $ Costs of non-compliance
- Understanding how a Civil Money Penalty is determined
- Ensure your management team and directors understand the severity of non-compliance
- Lesson you can apply to protect your institution
Areas will be covered during the Session
- Laws and regulations applicable to Enforcement Actions
- Policies and Procedures published by regulators
- Actual Examples of current Enforcement Actions
- Practices your institution can develop to hopefully avoid an Enforcement Action
- Enforcement Action implementation processes
By attending this webinar participants will obtain the information needed to fully understand the Enforcement Action process, they will gain valuable background information through reviewing regulators policies and procedures related to the implementation of Enforcement Actions, they will read and study real life examples which will show them what not to do, and they will obtain information they can use to ensure that their institution’s activity does not result in an Enforcement Action.
WHO WILL BENEFIT?
- BSA/AML Officers
- BSA/AML Auditors
- BSA/AML Staff
- Risk Managers
About Thomas Nollner
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 Controller of the Currency where he was a safety and soundness examiner and a compliance examiner. The last 15 years as an NBE 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 U S 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.
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