1. Fiduciary & Investment Risk Management Association
Financial Crimes in the Fiduciary and Wealth World
March 2012
    
C. Rachel Romijn Senior Vice President BSA and FCPA Manager Wealth, Brokerage, and Retirement Wells Fargo

2. Overview of Presentation
Unique and Not so Unique……
Not so….CIP, Monitoring
So….Source of Wealth Analysis, Reputational Risk, PEP Vetting
Not so and So…Geography Risk, Beneficial Ownership

3. Overview of a Strong AML/ATF/OFAC Program
WARRCOM
Written Policies and Procedures
Awareness and Training
Regulatory and Internal Reporting
Record keeping
Customer and Product Due Diligence
Oversight
Monitoring and Assessments
     

4. Not so Unique… Customer Identification Program (CIP)
     
Customer Identification Program (CIP)
Customer Due Diligence
Currency Transaction Reporting
Money Movement Monitoring
SAR Reporting

5. Unique to Wealth and Trust…
Source of Wealth Analysis…initial and on going
Reputational Risk
Large Relationships
High Profile Clients
Specialized Focused Training
PEPs
Offshore Companies and Trust
Direct and Visible Involvement of RM

6. Retail Brokerage Twist…
Securities Fraud Monitoring
Coordination Among, Through and with Legal Entities

7. Unique and Not so Unique…
Geography Risk….Independent in-country visits for certain types of clients
Beneficial Ownership

8. New Developments Beneficial Ownership….. deeper dive for all
Domestic PEPs???