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AMLA 3nd Annual BSA Conference
BSA/AML HOT TOPICS
October 4, 2013
Christopher Price
Senior Compliance Manager, Regulatory Advisory
Introduction and Overview
• Introduction
• BSA/AML Hot Topics
–Medical Marijuana
–Mortgage Lending
• Other BSA/AML Common Findings
BSA/AML Hot Topics
• Medical Marijuana
–State law vs. federal law
–Federal Regulatory expectations
–Standard and Enhanced CIP
–CDD and EDD
–Filing SARs
BSA/AML Hot Topics
• Mortgage Fraud
–Appraisal Fraud Red Flags
–Red Flags for Loan Modification Schemes
–Reverse Mortgage Fraud
–Developing procedures for service personnel off of RESPA servicing amendments
–The Case of Louis Gendason – Loan Officer
BSA/AML Hot Topics
• Other Common BSA/AML Issues
–Lack of system validation
– Issues with Independent Audit
–Risk Assessment is not adequate
–Program is not Enterprise Wide – does not cover all areas of the bank
Final BSA/AMLComments & Questions
Thank You!
Christopher PriceSenior Compliance Manager Regulatory Advisory ServicesFIS Enterprise Governance Risk and Compliance
800-547-2462 x75039 Office407-309-5039 Direct866-525-6716 [email protected]