2013 Conference Summary and Key Highlights
New Financial Intelligence Unit Created for SAR Reviews
Keynote speaker Cyrus Vance, Jr., Manhattan District Attorney, told conference attendees his office would launch a new financial intelligence unit to deal with the prosecution leads and trends uncovered in the SARs his office receives.
In addition to financial crimes, analysts will also investigate other illicit activities, including human trafficking, violent crime, and immigrant-related exploitation. "Sometimes, the first indication that we have of some of these kinds of syndicates operating in these areas…will come from a review of a SAR or a [currency transaction report]," said Vance.
Read a complete overview of the announcement by downloading the news release from ACAMS moneylaundering.com.
Monitoring New Product Trends and End-Users
CitiBank's Jim Stubbs, Managing Director and Global AML Head for Consumer and Cards, addressed an interesting dilemma: managing the launch of new products and, most importantly, the end-user. Stubbs asserts that compliance officers must keep a watchful eye on which customers are sold new products. In reference to new product launches, Stubbs says, "You don't want to see a product not do as well as anticipated so that the business line starts to push it down market to higher risk customers that it wasn't originally intended for."
Monumental Changes in Regulatory and Legal Environment
Adam Kaufmann, former chief of investigations in the Manhattan District Attorney's office, told attendees that the regulatory and legal environment had changed radically, and that nowhere was that more apparent than in remarks by Justice Department officials in announcing the HSBC deferred prosecution agreement. Mr. Kaufmann went on to say that federal prosecutors faulted the bank for criminal conduct for both sins of commission and omission.
Read a synopsis of the settlement and a speech by Assistant Attorney General Lanny Breuer by downloading the Legs/Regs document from ACAMS moneylaundering.com.
Vigilant Due Diligence is Vital
During a panel discussion highlighting correspondent banking, several key issues were addressed, including the importance of ongoing due diligence. According to Renato Giammarco, CAMS, a partner at Ernst & Young LLP, "you don't enter into a relationship with a money launderer." That someone may be engaged in such activities is something that develops and may only be revealed over time; accordingly ongoing, vigilant due diligence is crucial in the prevention of illicit crimes.
2nd Annual Conference
The 2nd Annual AML Risk Management Conference has been set for January 2014. Stay tuned for details and sign up to receive conference updates for next year's highly anticipated event.