14th Annual Forum on AML & OFAC Compliance for the Insurance Industry - WEB

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IN-PERSON & LIVESTREAM

February 13–14, 2024 • New York City Bar Association, NYC

14th Annual Forum on

AML & OFAC COMPLIANCE for the Insurance Industry Stay Ahead of the Rapidly Evolving AML & Economic Sanctions Landscape

2024 CONFERENCE CO-CHAIRS Sandra Calmes

Vice President, Senior Corporate Counsel, Global Financial Crimes Officer Liberty Mutual Insurance (WSN Member)

Luis Duarte

Senior Sanctions Compliance Manager Generali USA

Join the AML & OFAC Compliance event designed specifically for in-house counsel and compliance professionals at insurance and reinsurance companies, as well as their outside counsel, who are responsible for Anti-Money Laundering (AML) and OFAC compliance.

GOVERNMENT SPEAKERS: Claire Grunewald

Sanctions Compliance Officer Office of Foreign Asset Controls (OFAC) U.S. Department of Treasury

David Lim

Co-Director, Task Force KleptoCapture U.S. Department of Justice

Supporting Sponsor

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Associate Sponsor

FEATURED SPEAKERS: Andrew Gifford

Global General Counsel and Secretary General Re

Mark O. Huard, FCLS, CIFI

Special Agent, Northeast Region National Insurance Crime Bureau

Kaneez F. Madraswalla Vice President, Compliance QBE North America

Kelvin K. Miller

Charles Smith

Vice President, Global Head of Anti-Financial Crime Compliance MetLife

Senior Counsel, Economic and Trade Sanctions Travelers Insurance Co. Former Senior Sanctions Investigator, Office of Foreign Assets Control (OFAC)

Cocktail Reception Sponsor

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AGENDA AT A GLANCE • February 13–14, 2024 MAIN CONFERENCE DAY 1

MAIN CONFERENCE DAY 2

Tuesday, February 13, 2024 • 8:00 am – 5:00 pm

Wednesday, February 14, 2024 • 8:00 am – 12:00 pm

8:00 am

Networking Breakfast and Registration

8:00 am

Networking Breakfast and Registration

9:00 am

Opening Remarks from the Co-Chairs

9:00 am

Opening Remarks from the Co-Chairs

9:10 am

OFAC Keynote

9:10 am

9:45 am

Keeping Up with Russia Sanctions: Unravelling Key Developments and New, Far-Reaching Russia Sanctions Impacting the Insurance Industry

International Perspectives: Navigating Evolving International Sanctions and AML Complexities for the Insurance Industry

Networking Break

10:00 am

10:45 am

Enforcement Outlook: What Insurance Companies Can Expect in an Aggressive AML and Sanctions Enforcement Climate

11:00 am

Exploring Key Uses and Risks of AI in BSA/AML Compliance: Opportunities and Challenges for Insurance Companies

10:30 am

Networking Break

11:45 am

Sanctions Evasion and Circumvention: Examining the Current Landscape of Evasion Typologies, Threats, and Risks; How Insurance Companies Can Stay Prepared for the Newest, Most-Sophisticated Techniques

10:45 am

AML, Sanctions, and Whistleblowers: Developing a Risk-Based Approach to AML and Sanctions Programs for Insurers and Tackling Risks Posed by the New FinCEN and OFAC Whistleblower Reward Programs Among Other Risks

12:30 pm

Networking Luncheon

11:30 am

Complying with the Corporate Transparency Act: Navigating the CTA and Complying with FinCEN’s Beneficial Owner Reporting Rules

1:45 pm

Strengthening Your Sanctions Screening Program: Components of an Effective, Risk-based Sanctions and Export Compliance Program and Guidance on Updated OFAC Requirements

12:00 pm

Closing Remarks from the Co-Chairs and Conference Adjourns

2:30 pm

Guidance on the SEC’s Cybersecurity Disclosure Rule: Best Practices for Compliance with Disclosures Related to Cybersecurity Risk Management, Strategy, and Governance for Insurance and Reinsurance Companies

3:15 pm

Networking Break

3:45 pm

Small Group Networking Discussion by Sector AML Compliance Hot Topics: A – Life Insurance Sector C – Property & Casualty B – Maritime Insurance Sector Insurance Sector

5:00 pm

Day 1 Adjourns to Networking Cocktail Reception Sponsored by

POST-CONFERENCE WORKSHOP

Wednesday, February 14, 2024 • 1:30 pm – 5:00 pm Breaking Down the Nuts and Bolts of FinCEN’s Compliance Guidance on the AML Act of 2020: From Risk Assessments, Internal Controls and Policies to Third-Party Risk Management

Media Partner

Join this exclusive legal and compliance cross-industry community!

WOMEN IN SANCTIONS NETWORK

The Women in Sanctions Network (WSN) is a global community of like-minded women working in economic sanctions. The WSN is committed to promoting diversity across the profession, creating worthwhile networking and educational programs, and updating members on employment and advancement opportunities .

Join our Women in Economic Sanctions Membership: WomenSanctionsNetwork.com

2 | LINKEDIN Financial Services: Legal, Regulatory, and Compliance Professionals

2024 SPEAKER FACULTY GOVERNMENT Claire Grunewald Sanctions Compliance Officer Office of Foreign Asset Controls (OFAC) U.S. Department of Treasury David Lim Co-Director, Task Force KleptoCapture U.S. Department of Justice

CO-CHAIRS Sandra Calmes Vice President, Senior Corporate Counsel, Global Financial Crimes Officer Liberty Mutual Insurance (WSN Member) Luis Duarte Senior Sanctions Compliance Manager Generali USA

INDUSTRY SPEAKERS AND THOUGHTLEADERS Jesse Aedo Group Head of Compliance Aspen Angela Bates AML and Sanctions Senior Compliance Officer Corebridge Financial

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LAW FIRMS Bridget Choi Cyber Product Lead Woodruff Sawyer

Steve Marshall Director, Advisory Services FinScan

Marcus Asner Partner Arnold Porter

Evanthia Coffee Senior Lawyer Gard AS

Richard McDermott Global Sanctions Program Director AmTrust Financial Services

Justine Clark Of Counsel Moses Singer

Dana Cordes AVP, Anti-Financial Crimes Compliance MetLife

Kelvin K. Miller Senior Counsel, Economic and Trade Sanctions Travelers

Melanie Garcia Partner DLA Piper LLP (US)

Rob Drouin Manager, Engineering; Lead, Technology, Global Compliance and Ethics Liberty Mutual Insurance

Kelly Pirrotta Head of AML, Economic Sanctions and Senior Financial Exploitation MassMutual

Andrew Gifford Global General Counsel and Secretary General Re Michael Heffernan Director, Global Financial Crimes Liberty Mutual Insurance

Scott Stransky Managing Director, Head of Cyber Risk Intelligence Center Marsh McLennan

Hrishikesh Hari Partner Dechert LLP Mary Inman Partner Constantine Cannon LLP John Keough Partner Clyde & Co.

Scott Horton Associate General Counsel, Global Head of Financial Crimes AIG

Sven Stumbauer National Managing Director, Anti-Money Laundering and Sanctions Practice Leader Grant Thornton LLP (US)

Mark O. Huard, FCLS, CIFI Special Agent, Northeast Region National Insurance Crime Bureau

Benjamin Trent AML and OFAC Compliance Auditor Grant Thornton LLP (US)

Britt Mosman Partner Willkie Farr & Gallagher LLP

Kaneez F. Madraswalla Vice President, Compliance QBE North America

Inna Tsimerman Chief International Trade Counsel Arthur J. Gallagher & Co. (WSN Member)

Jim Slear Principal Slear Law

Satish M. Kini Partner Debevoise & Plimpton LLP

CONTINUING LEGAL EDUCATION CREDITS

Accreditation will be sought in those jurisdictions requested by the registrants which have continuing education requirements. This course is identified as nontransitional for the purposes of CLE accreditation.

ACI certifies this activity has been approved for CLE credit by the New York State Continuing Legal Education Board.

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Charles Smith Vice President, Global Head of Anti-Financial Crime Compliance MetLife

Arlette Grabczynska Of Counsel DLA Piper LLP (US)

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ACI certifies this activity has been approved for CLE credit by the State Bar of California.

ACI has a dedicated team which processes requests for state approval. Please note that event accreditation varies by state and ACI will make every effort to process your request.

Questions about CLE credits for your state? Visit our online CLE Help Center at www.AmericanConference.com/Accreditation/CLE/ Part of C5 Group’s ECONOMIC SANCTIONS GLOBAL SERIES

MAIN CONFERENCE DAY 1 Tuesday, February 13, 2024

8:00 am Networking Breakfast and Registration 9:00 am

10:45 am Networking Break 11:00 am

Exploring Key Uses and Risks of AI in BSA/AML Compliance: Opportunities and Challenges for Insurance Companies microphone-alt MODERATOR: Luis Duarte, Senior Sanctions Compliance Manager, Generali USA

Opening Remarks from the Co-Chairs

Michael Heffernan, Director, Global Financial Crimes, Liberty Mutual Insurance

microphone-alt Sandra Calmes, Vice President, Senior Corporate Counsel, Global Financial Crimes Officer, Liberty Mutual Insurance

Rob Drouin, Manager, Engineering; and Lead of Technology, Global Compliance and Ethics, Liberty Mutual Insurance

Luis Duarte, S enior Sanctions Compliance Manager, Generali USA 9:10 am

OFAC Keynote microphone-alt Claire Grunewald, Sanctions Compliance Officer, O ffice of Foreign Asset Controls (OFAC), U.S. Department of Treasury 9:45 am

Keeping Up with Russia Sanctions: Unravelling Key Developments and New, Far-Reaching Russia Sanctions Impacting the Insurance Industry microphone-alt MODERATOR: Melanie Garcia, Partner, D LA Piper LLP (US) Dana Cordes, AVP, Anti-Financial Crimes Compliance, MetLife David Lim, Co-Director, Task Force KleptoCapture, U.S. Department of Justice Richard McDermott, Global Sanctions Program Director, AmTrust Financial Services Britt Mosman, Partner, Willkie Farr & Gallagher As the U.S. continues to impose severe and far-reaching economic sanctions on Russia, insurers must keep up with a barrage of new rules. The rapidly changing sanctions regime signals an urgent need for firms and companies to ensure processes are robust and that proper due diligence is in place.

Given the potential legal and financial consequences related to a raft of challenges from sanctions targeting Russia, insurance and reinsurance companies must unravel a complex web of unprecedented and rapidly changing economic sanctions. During this panel, we will explore key areas including: • Implementing robust processes to ensure proper due diligence • Navigating key differences between US, UK, and EU restrictions • Ensuring risk-based compliance programs in response to expansive use of sanctions and new methods of evasion • Navigating challenges related to the Russian Oil Price Cap for insurers • Understanding the expansive scope and targets for the latest sanctions

4 | LINKEDIN Financial Services: Legal, Regulatory, and Compliance Professionals

AI and emerging technologies are ushering in a new era of efficiency and effectiveness for compliance in the insurance sector. During this panel, we will explore the myriad ways that AI and other emerging technologies are reshaping AML compliance in the insurance industry through increased risk assessment precision, real-time monitoring, automating reporting, adaptive compliance, and a host of other solutions. During this panel, we will explore: • Leveraging AI-driven technologies to quickly detect fraud and AML risk • Using AI for advanced risk assessment to assess customer risk profiles • Implementing real-time transaction monitoring • Streamlining complex reporting requirements • Ensuring accurate and timely regulatory submissions 11:45 am

Sanctions Evasion and Circumvention: Examining the Current Landscape of Evasion Typologies, Threats, and Risks; How Insurance Companies Can Stay Prepared for the Newest, MostSophisticated Techniques microphone-alt Marcus Asner, Partner, Arnold Porter Sandra Calmes, Vice President, Senior Corporate Counsel, Global Financial Crimes Officer, Liberty Mutual Insurance Evanthia Coffee, Senior Lawyer, Gard AS An evolution in evasion techniques means a new wave of compliance risks for financial institutions and the wider industry, requiring robust adaptation and constant vigilance. Our expert panel will examine what constitutes sanctions evasion/circumvention, the current landscape of evasion threats, risks, and typologies, and practical tips for identifying them and being prepared, including: • Assessing the current landscape of sanctions evasion risks and typologies • Key methods for detecting and preventing circumvention of sanctions • Best practices for carrying out risk assessments and sanctions compliance • Identifying indications of circumvention of sanctions through third countries • Understanding the new efforts to prosecute sanctions evasion 12:30 pm Networking Luncheon

1:45 pm

Strengthening Your Sanctions Screening Program: Components of an Effective, Risk-based Sanctions and Export Compliance Program and Guidance on Updated OFAC Requirements microphone-alt MODERATOR: Jim Slear, Principal, Slear Law Andrew Gifford, Global General Counsel and Secretary, G en Re Kelvin K. Miller, Senior Counsel, Economic and Trade Sanctions, T ravelers

Former Senior Sanctions Investigator, O ffice of Foreign Assets Control (OFAC)

• Enhancing cybersecurity capabilities as you plan for new disclosure requirements and timely disclosure of material incidents • Strengthening your overall cybersecurity posture • Enhancing processes and procedures to meet disclosure requirements 3:15 pm Networking Break 3:45 pm

Small Group Networking Discussion by Sector: AML Compliance Hot Topics

Enhancing the effectiveness of your sanctions screening program is critical in today's stringent regulatory landscape. This entails robust due diligence processes, continuous monitoring, and the implementation of state-of-the-art screening tools and technologies. Strengthening your sanctions screening program not only safeguards your organization from legal repercussions, but also contributes to the broader efforts of maintaining global security and stability by preventing illicit financial activities. During this panel, we will explore:

ROUNDTABLE A – LIFE INSURANCE

• Addressing rapidly changing geopolitical events and risk factors

ROUNDTABLE B – MARITIME INSURANCE

• Utilizing enhanced screening tools, including IP blocking and geofencing • Improving sanctions screening protocols for better compliance • Ensuring data accuracy and minimizing false positives • Documenting risk assessments related to compliance with sanctions 2:30 pm

Guidance on the SEC’s Cybersecurity Disclosure Rule: Best Practices for Compliance with Disclosures Related to Cybersecurity Risk Management, Strategy, and Governance for Insurance and Reinsurance Companies microphone-alt Scott Stransky, Managing Director, Head of the Cyber Risk Intelligence Center, Marsh McLennan Bridget Choi, Cyber Product Lead, W oodruff Sawyer On July 26, the SEC adopted amendments intended to enhance and standardize disclosures related to cybersecurity. The amendments require companies timely to disclose material cybersecurity incidents and annual disclosures related to cybersecurity risk management, strategy, and governance in a timely manner.

During this panel, we will discuss the new SEC regulations and the requirements for public companies to provide investors with information about cybersecurity risk management programs. During this panel, we will discuss: • Countering illicit finance associated with cyber-enabled crime • Communicating essential information about your cyber risk management program and cybersecurity performance with stakeholders

microphone-alt Angela Bates, A ML and Sanctions Senior Compliance Officer, Corebridge Financial Kelly Pirrotta, CAMS, Head of AML, Economic Sanctions, and Senior Financial Exploitation, MassMutual

microphone-alt John Keough, Partner, Clyde & Co. ROUNDTABLE C – PROPERTY & CASUALTY INSURANCE microphone-alt Mark O. Huard, Special Agent, Northeast Region, National Insurance Crime Bureau Kaneez F. Madraswalla, Vice President, Compliance, QBE North America Our sector-specific roundtables are a platform for industry professionals to engage in focused discussions involving current regulatory and compliance challenges. These roundtables foster collaboration and knowledge-sharing, allowing participants to gain insights into emerging trends and best practices through collaborative round-table discussion.

5:00 pm Closing Remarks from the Co-Chairs and Day 1 Adjourns

Cocktail Reception Sponsored by

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• Determining the materiality of a cybersecurity incident

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MAIN CONFERENCE DAY 2 Wednesday, February 14, 2024

8:00 am Networking Breakfast and Registration 9:00 am

Opening Remarks from the Co-Chairs microphone-alt Sandra Calmes, Vice President, Senior Corporate Counsel, Global Financial Crimes Officer, Liberty Mutual Insurance Luis Duarte, S enior Sanctions Compliance Manager, Generali USA 9:10 am

International Perspectives: Navigating Evolving International Sanctions and AML Complexities for the Insurance Industry microphone-alt MODERATOR: Inna Tsimerman, Chief International Trade Counsel, Arthur J. Gallagher & Co. (WSN Member) Arlette Grabczynska, O f Counsel, DLA Piper LLP (US) Scott Horton, Associate General Counsel and Global Head of Financial Crimes, AIG Steve Marshall, Director, Advisory Services, FinScan A comprehensive examination of the US, EU, and UK sanctions structures and AML guidelines reveals an intricate interplay between legal frameworks, policy objectives, and enforcement challenges. During this panel, we will explore the intricate nature of the global sanctions and AML frameworks, including: • An overview of policy objectives and the diversity of sanctions structures • The effectiveness of sanctions based on enforcement mechanisms • The interplay between diplomatic engagement and punitive measures • How federal, provincial, and territorial governments are working on transparency and updates to key milestones of collaboration • Discussion of multilateral sanctions engagement • Implications of sanctions changes in the UK and EU on sanctions compliance generally 10:00 am

Enforcement Outlook: What Insurance Companies Can Expect in an Aggressive AML and Sanctions Enforcement Climate microphone-alt Justine M. Clark, Of Counsel, Moses Singer

10:45 am

AML, Sanctions, and Whistleblowers: Developing a Risk-Based Approach to AML and Sanctions Programs for Insurers and Tackling Risks Posed by the New FinCEN and OFAC Whistleblower Reward Programs Among Other Risks microphone-alt Jesse Aedo, G roup Head of Compliance, Aspen Insurance Group Mary Inman, Partner, Constantine Cannon LLP Developing a risk-based approach to AML & sanctions programs is essential for insurers and reinsurers in today's complex regulatory landscape. Companies must be vigilant in identifying and mitigating money laundering and sanctions risks while efficiently allocating resources. Effective risk-assessment strategies are critical to achieving compliance and protecting the integrity of the insurance industry. During this panel, we will discuss key considerations: • Implementing a robust Customer Due Diligence (CDD) process • Utilizing advances data analytics tools to monitor transactions • Fostering a culture of compliance within the organization • Encouraging a proactive approach to risk identification and reporting 11:30 am

Complying with the Corporate Transparency Act: Navigating the CTA and Complying with FinCEN’s Beneficial Owner Reporting Rules microphone-alt Charles Smith, Vice President, Global Head of Anti-Financial Crime Compliance, MetLife Satish M. Kini, Partner, D ebevoise & Plimpton The CTA, a component of the Anti-Money Laundering Act of 2020 implemented by FinCEN, was enacted to prevent money laundering, terrorist financing, and other illicit activities. It takes effect January 1, 2024. By increasing the information reported on business entities, the CTA aims to prevent the exploitation of U.S. corporations and LLCs for criminal gain and assist law enforcement in detecting criminal activity. The CTA requires companies, beneficial owners, and business applicants to file information with the U.S. Department of the Treasury. During this panel, we will explore: • Understanding the compliance requirements related to the CTA • Understanding the potential penalties for failing to report • Breaking down the Beneficial Ownership Reporting rules under the CTA 12:00 pm Closing Remarks and Conference Adjourns

Hrishikesh N. Hari, Partner, Dechert LLP • An overview of the U.S. government’s current enforcement of violations of sanctions and AML laws • Facing significant potential exposure for violations, what are current best practices for insurance and reinsurance companies?

• Recent enforcement examples in adjacent industries and important lessons for the insurance industry 10:30 am Networking Break

6 | LINKEDIN Financial Services: Legal, Regulatory, and Compliance Professionals

Supporting Sponsor Leading global sanctions and export controls team with comprehensive sector experience and top government advisors including Senate Intelligence Committee Chairman and White House National Intelligence.

POST-CONFERENCE WORKSHOP* Wednesday, February 14, 2024 1:30 pm (Registeration at 12:30 pm)

Breaking Down the Nuts and Bolts of FinCEN’s Compliance Guidance on the AML Act of 2020: From Risk Assessments, Internal Controls and Policies to Third-Party Risk Management microphone-alt Sven Stumbauer, National Managing Director, Anti-Money Laundering and Sanctions Practice Leader, Grant Thornton LLP (US) Benjamin Trent, AML and OFAC Compliance Auditor, Grant Thornton LLP (US) This workshop will provide attendees with a deep dive practical look at how the industry is putting compliance into practice including the compliance risks of data and technology. The attendees will have the opportunity to break out discussion on topics most relevant to them.

Part I: AML Act of 2020 • FinCEN National Priorities: How firms are getting ready for the upcoming national exam regulation, a framework for compliance.

• FinCEN National Priority: Fraud • How fraudsters are using technology to launder money and evade Sanctions and how law enforcement is catching them.

• FinCEN National Priority: Corruption • Recent enforcement actions and root causes of compliance failures. Best practices for your ABC program.

• FinCEN National Priority: Proliferation Financing

* In-Person Participation Only.

• Recent enforcement actions related to Sanctions of the Russian military industrial complex.

Root causes of compliance failures and an effective framework for managing the risks of customers in high-risk industries.

• Corporate Transparency Act • How lessons learned from the U.K. can help us implement the new Corporate Transparency Act regulations in our compliance programs.

• Regulatory Focus on KYC • Lessons learned from the most recent enforcement actions and how firms are addressing the highest priority issues.

Part II: Sanctions Compliance and Enforcement • Global Survey of Sanctions Compliance Professionals • The global sentiment on the changing Sanctions environment, how firms worldwide are addressing the challenges • AML and Sanctions Technology Enforcement Actions • Understanding the regulatory focus on technology and data, the most common deficiencies, and the most effective frameworks for managing compliance program technology risks.

• Sanctions Name Screening and Technology • How to tailor testing, tuning, and screening procedures to align with regulations, guidance, and recent enforcement actions.

• Third-party Risk Management • Lessons learned from AML and OFAC enforcement actions and best practices for managing affiliate risk.

5:00 pm Workshop Concludes

 C5 celebrates 40 years of excellence! We are thrilled to have provided exceptional conference experiences globally with our outstanding team, speakers, sponsors, partners, and attendees. To mark this milestone, we're launching a new logo which represents our commitment to innovation, growth, and excellence, represented by the five Cs of C5: Current, Connected, Customer-Centric, Conscientious, and Committed.

Looking back on 40 years, we are grateful for our achievements—hosting global conferences, uniting industry leaders, and supporting business growth. However, we are not done yet! We are committed to pushing boundaries and creating impactful experiences and we're excited for the next 40 years of success.

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American Conference Institute is pleased to offer our delegates a limited number of hotel rooms at a negotiated rate at the Sofitel Hotel. To take advantage of these rates, please contact the hotel directly and quote "ACI’s AML & OFAC Insurance".

HOTEL: Sofitel New York ADDRESS: 45 West 44th Street RESERVATIONS: Sandra.Schoeffler@sofitel.com or 212-782-3021 ONLINE: To reserve online, CLICK HERE Please note that the guest room block cut-off date is January 12, 2024. After that date OR when the room block fills, guestroom availability and rate can no longer be guaranteed.

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Luis Santos Director

Ramesh Kumar Partner

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2024 CONFERENCE CO-CHAIRS Sandra Calmes

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Luis Duarte de Jesus

AVP & Senior Corporate Counsel, Global Compliance and Global Financial Crimes Liberty Mutual Insurance

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