Disclosures to Law Enforcement

On Demand 24/7. Closed Captioning Included.

Responding to information requests from Law Enforcement can be tricky. A financial institution has a legal responsibility to provide information to law enforcement, but the communication must be disciplined and take place inside the rules. This video explains the rules of the customer information disclosure road. It not only explains the how’s and when’s of disclosure, but the requirements of a good policy and procedure to guide the response. The video contains a real world example which is unpacked for your information.

The video was presented by seasoned professionals who have wide and deep experience, including a representative of Law Enforcement who provides insights not often seen by financial institution BSA/AML professionals.

View the video with the button below. If you want to a download link, click the link and the BSA Coalition will consider it.

How to Risk-Focus Your BSA/AML Risk Assessment.

On Demand 24/7.

Let’s get this out of the way, up front: the BSA/AML/OFAC risk assessment is not simple.  It’s not easy.  Doing it correctly means lots of research and data gathering.  It means building an analysis tool.   Prepare yourself to work hard, over several weeks.

Financial institutions should remember the Risk Assessment is not optional.  It is required by regulation.  It must be done correctly because the Risk Assessment is a key tool in (a) managing the institution’s risk and (b) guiding the institution’s business process.

This video was prepared to help prepare a Risk Assessment that meets regulatory expectations and genuinely benefits your institution.  It explains what is needed, how you go about gathering all the information and what you do with it.

The Regulatory Expectation

Financial institution examiners expect the Risk Assessment to be deliberate and thorough – in fact, there is increasing pressure to produce a more robust risk assessment, with more detail on the following:

• types of customers (especially business customers),
• geographical location (especially out of market or in HIDTA/HIFCA areas),
• “enhanced features”, like ACH and Remote Deposit, associated with the base account, and
• relevance of the risk assessment (identify and evaluate risks specific to your institution.)

The Risk Assessment is meant to exist in context to events inside and outside the institution.  The BSA/AML risk assessment should result in a reasonable institution Risk Profile, often expressed as a score which, in turn, results in a narrative profile of, for example, “moderate”, or “moderate to high”.

The regulatory expectation is that

(a) the Risk Profile be dynamic, responsive to changing internal and external conditions and

(b) executed not just periodically as a matter of course, but in response to material events: significant changes in loan or deposit portfolio content, loss of key employees, opening or closing of an office, etc.

The Risk Profile and Risk Assessment are expected to be a management monitoring tool to guide the business process.  In other words, before any business decision, one of the key questions would be, “How will this contemplated action affect our Risk Profile?”

About our webcasts

Covid inspired us to broaden our outreach to members with Coalition Webcasts.  The webcast doesn’t’ require advance registration.  It can be viewed upon demand.  Plus, the webcast can easily include Closed Captioning, Transcripts and Slide Decks specifically tailored to the subject.  Webcasts, like all Coalition tools and resources are free.

The Coalition, which is a non-profit organization,  constantly surveys members to learn of topics and speakers that are  of particular interest.  We strive to keep our events timely and chock full of meaningful information.  We want to provide information that can be put to immediate use inside our member’s institutions.  If you would like to pass along a suggested topic for an event or if you have a presenter you have seen and liked, let us know.  We have a special Members Comment form for this purpose.  Find it here.

The views and opinions expressed in the webcasts are those of the speakers.  They do not represent legal advice, an official position of any regulatory agency, financial institution, or Board of the BSA Coalition.