Mitigating Regulatory Criticism of Your Bank's KYC EDD Program
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Withum and AML Partners with a number of senior Bank Secrecy Act Anti-Money Laundering compliance leaders discuss best practices in Know Your Customer program (KYC CDD EDD) regulations and also to share what their personal challenges that they have faced in their roles for KYC compliance.
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Mitigating Regulatory Criticism of Your Bank's KYC EDD Program
- 1. withum.com Mitigating Regulatory Criticism of Your Bank’s KYC EDD Program Roundtable Discussion May 7, 2020
- 2. withum.com Agenda and Objectives • Introductions • Housekeeping Rules • Co-Host and Moderator: Peter Kim – Principal, Withum • Co-Host and Moderator: Jonathan Almeida – Founder, AML Partners • Agenda – Topics for Discussion • Panelists • Kevin Choi – Deputy BSA Officer, SMBC (Sumitomo Mitsui Banking Corp.) • Micah Hallock – BSA Compliance Officer, NongHyup Bank • Abel Picardi – Former Chief Compliance Officer, Bank of China • Agenda Topic Points • Questions from the Audience • Closing • Questionnaire • Closeout
- 4. withum.com Co-Hosts and Moderators Peter Kim, CAMS • Principal in Withum’s Forensic and Valuation Services Group specializing in regulatory compliance. • Extensive experience and a diverse background as a former federal regulator, financial services consultant and compliance leader with various financial institutions
- 5. withum.com Co-Hosts and Moderators Jonathan Almeida • Founder & Global Head of Sales and Business Development of AML Partners • Designers of [RegTech One], a #NOCODE platform allowing FIs to design their own KYC Workflows, Risk Models, UBO collection, CDD/EDD, PEP/Sanctions/Media Screening etc.
- 7. withum.com Panelists Kevin Choi • Deputy BSA Compliance Officer, Sumitomo Mitsui Banking Corp, NY Branch / AML Compliance Officer and Money Laundering Reporting Officer, SMBC (Sumitomo Mitsui Banking Corp.), Cayman Branch • Former CCO and BSA Officer, Israel Discount Bank of NY • Former Federal Reserve Bank regulator
- 8. withum.com Panelists Micah Hallock • BSA Compliance Officer, NongHyup Bank • Former BSA Officer, SHBA Bank • Former OCC Examiner
- 9. withum.com Panelists Abel Picardi • Former Chief Compliance Officer, Bank of China • Former Federal Reserve Bank Examiner
- 10. withum.com Disclaimer • Contents and statements made in this event are strictly the opinions of individual participants. • Contents and statements made in the event are not recommendations or intended as guidance on regulatory requirements.
- 12. withum.com On UBO • Talk us through obtaining UBO information in terms of how the information is sourced 1. At the time of OnBoarding 2. On Refresh/Review and what would that schedule be • A follow up is, how reliable are the sources and is the % of ownership collected, Risk based? • Use and applications of CDD exemptions?
- 13. withum.com On Adverse Media / Negative News • What information is generally screened besides Customers? • i.e. UBO, Signatories, Guarantors, Board Members etc. • Are the types of names screened based on Customer Risk? • What is good practice pertaining the frequency of screening after being initially performed during OnBoarding? • Is it based on Risk, on a particular schedule?
- 14. withum.com On Periodic Review • In terms of defining a Periodic Review schedule, what is generally a good practice? • And a follow up to that is, how do each of your institutions track upcoming reviews? • What in general are the tasks that are performed, are customer re-contacted to have them confirm any changes?
- 15. withum.com Bank Organization and KYC Tools • Head office vs local branch/agency, how to address the issue of transparency between different parts of the bank from KYC EDD perspective • Are you using a KYC system? If so what are the critical requirements that you would need the system to satisfy?
- 16. withum.com Best Practices and Unique Challenges • What has worked for banks and how enhancements, systems, tools and processes mitigated regulatory criticism? • Best practices • What are the unique challenges that banks face with KYC EDD program?
- 19. withum.com Questionnaire About the Session Scale of 1 – 10 (best) • Ease of Use of the virtual media • Knowledge of two moderators • Knowledge of three speakers • Agenda topics • Interest in attending another session if held on other topics • Obtain topic recommendations from the audience • Are more visuals needed, camera or is voice sufficient?
- 20. withum.com Questionnaire to the Audience on their KYC program
- 21. withum.com Audience Questionnaire KYC Program Do KYC Officers decide when Enhanced Due Diligence is needed?
- 22. withum.com Audience Questionnaire KYC Program During account opening, does your On-Boarding process use paper-based forms?
- 23. withum.com Audience Questionnaire KYC Program Is Customer Risk calculated manually via Excel sheets or automatically via a KYC System?
- 24. withum.com Audience Questionnaire KYC Program Average On-Boarding duration of ‘Corporates’?
- 25. withum.com Audience Questionnaire KYC Program Average On-Boarding duration of ‘Financial Institutions’?
- 26. withum.com Audience Questionnaire KYC Program How are expiring documents (eg. Patriot Act Certificates, Audited Financials, UBO Passports etc) tracked?
- 27. withum.com Audience Questionnaire KYC Program Is there a centralized dashboard to present the State of KYC (eg. Customer Risk Chart, OnBoarding Status, Periodic Review Tracking etc)
- 28. withum.com Thank You to Our Speakers Panelists Kevin Choi Deputy BSA Officer, SMBC (Sumitomo Mitsui Banking Corp.) kevin_choi@smbcgroup.com Micah Hallock BSA Compliance Officer, NongHyup Bank mthallock@nhbankny.com Abel Picardi Former Chief Compliance Officer, Bank of China abel33@netzero.net Moderators Peter Kim Principal, Withum p.kim@withum.com Jonathan Almeida Founder, AML Partners jonathan@amlpartners.com
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- Peter and Jonathan to open
- Peter to introduce himself
- Jonathan to introduce himself
- Kevin to introduce himself
- Micah to introduce himself
- Abel to introduce himself
- Kevin to answer UBO questions
- Micah to answer Adverse Media/Negative News questions
- Abel to answer Periodic Review questions
- All to answer Bank organization and KYC tools question.
- All to answer Best Practices and Unique Challenges questions.
- Remind viewers that a survey will pop up at the conclusion of the webinar
- Will share data as we receive it.