1. Hot Topics in BSA/AML September 21, 2016 BCAC Office of the Comptroller of the Currency Laura M. Lewis Northeastern District Compliance Lead Expert Deborah Herrmann National Bank Examiner

2. BSA/AML Examination Focus Evaluate overall BSA/AML/OFAC management program Review and validate independent audit Evaluate risk assessment Assess suspicious activity and reporting systems 2

3. BSA/AML Examination Focus Review of internal controls Evaluate BSA Officer - and staff, if applicable Assess training program 3

4. BSA/AML Findings and Concerns Violations and MRAs are trending up - many repeats Programs not keeping up with bank growth or changes Underestimate time and staff needed for automated systems BSA Officer turnover 4

5. BSA/AML Findings and Concerns Conflicts of auditor for small institutions Lack of depth in BSA staff Issues with high-risk customer identification/monitoring Omit new product or service from RAS and IC Weak or non-existent CDD/EDD program/process 5

6. BSA/AML Emerging/Growing Issues Risk re-evaluation ?? (MSBs, third party payment processors, etc.) Emerging technologies and their added risks Trade-Based Money Laundering Legalization of Marijuana New rules on CIP for prepaid access devices 6

7. BSA/AML Emerging/Growing Issues New emphasis on CDD/EDD Implementation and on-going tuning of new or existing automated suspicious activity monitoring systems Use of funnel accounts for ML Human trafficking 7

8. BSA/AML Emerging/Growing Issues Elder abuse Frequently Changing OFAC Rules IP Addresses Panama papers Terrorist financing 8

9. BSA/AML Reminders Reliance on third party relationships can significantly increase your risk profile Banks are offering new products and services or altering existing products and services with different fees, pricing structures and customers Compliance with legal requirements is critical, and assessment is based on transaction testing 9

10. BSA/AML Reminders Examiners assess BOD and senior management support, competency and adequacy of staff, culture, and independence and influence of BSA officer 10

11. QUESTIONS ??? 11