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2015 2015
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March 5 th & 6 th 2015
Hyatt Regency Hotel
Miami, FL
Staying Alive: the Regulatory Storm the Regulatory Storm Staying Alive:How HowtotoSurvive Survive the Regulatory Storm
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Platinum Sponsor
Con Traducción Simultánea (Inglés/Español)
www.FIBAAML.com
(305) 579-0086
2015
A
FIBA AML CONFERENCE
Confirmed Speakers
Claude Arnold
Alcides I. Avila
AndrĂŠs Carriquiry
Don Childears
Ana Maria de Alba
Michael Dondarski
Jamal El-Hindi
Andres A. Fernandez
Carl A. Fornaris
William J. Fox
Susan Galli
Jeff Horowitz
Lester M. Joseph
Adam Kaufmann
Walter J. Mix III
Arthur D. Middlemiss
Jim Richards
Amy Rudnick
Jennifer Shasky Calvery
Marivaldo P. Soares
Dan Stipano
James D. Stubbs
Natasha Taft
Frank Vogl
Special Agent in Charge, Los Angeles, Homeland Security Investigations U.S. Immigration & Customs Enforcement
Associate Director for the Regulatory Policy and Programs Division Financial Crimes Enforcement Network (FinCEN)
Manager, Global Financial Crimes Intelligence Group Wells Fargo & Company
Director Financial Crimes Enforcement Network (FinCEN)
Founding Partner, Corporate & Financial Services Avila, Rodriguez, Hernandez, Mena & Ferri (ARHMF)
Partner Holland & Knight LLP
Partner Lewis, Baach, Kauffmann, Middlemiss Pllc
Senior Compliance Officer Banco do Brasil
Chief Compliance Officer Banco de la RepĂşblica Oriental del Uruguay
Partner Greenberg Traurug, P.A.
Managing Director and Financial Services Practice Group Leader, Berkeley Research Group, Chairman, International Bankers Association Of California
Deputy Chief Counsel Office of the Controller of the Currency (OCC)
President and CEO Colorado Bankers Association
Managing Director of Global Financial Crimes, Corruption & Sanctions Bank Of America
Partner Lewis, Baach, Kauffmann, Middlemiiss Pllc
Managing Director, Deputy Head of Global AML Citigroup
Founder, President & CEO CSMB
Managing Director Financial Services Advisory PwC
EVP, BSA Officer & Head of Financial Crimes Risk Management Wells Fargo & Co.
Chief Compliance Officer Agricultural Bank of China- New York Branch
Chief, Regulated Industries, Oversight & Evaluation Office of Foreign Assets Control (OFAC)
Managing Director, Chief Compliance Officer Pershing
Partner Gibson Dunn & Crutcher
President Vogl Communications Inc.
Experience the 2015 FIBA AML Compliance Conference The industry’s premier gathering place of the most senior compliance executives worldwide assuring regulations, best practices and networking are at the top of the agenda.
Join an outstanding roster of leading industry members and experts in discussing the challenges and th opportunities facing the industry at the 15 Annual FIBA AML Compliance Conference taking place on th th March 5 and 6 , 2015 at the Hyatt Regency Hotel in Miami, Florida. Keep up as the latest news and highlights are revealed during this much anticipated annual gathering. Prospective attendees can, as always, look forward to an event that will prepare them for yet another year as successful AML professionals. • Learn what you need for your job in role-focused conference sessions • Hear up-to-date insights about emerging methods of economic crime • Engage in dialogue to delve deeper into the latest international requirements • Benefit from a wealth of real world case studies and best practices • Network with your peers and industry experts to get the real inside story from those in the know • Experience cutting-edge solutions first hand at the interactive exhibition hall The conference theme this year will be Staying Alive: How to Survive the Regulatory Storm and will include presentations, panel discussions, networking opportunities and so much more. As attendees of previous FIBA AML Conferences can attest, the event brings together the top experts and speakers from across the financial sector. It also offers a valuable opportunity to learn from others’ experience and hear about industry best practices that work.
What’s New in the AML Landscape? Senior compliance executives and risk managers from the financial services industry together with regulators discuss current issues and emerging trends in the fight against money laundering and terrorist financing. Broker-dealers Anti-Money Laundering Compliance Broker-dealers’ AML obligations continue to expand in order to comply with BSA and AML regulations and to meet regulatory expectations. The panel will discuss FinCEN’s proposed rule regarding beneficial ownership, regulatory expectations and common examination findings, FATCA, and Anti-Money Laundering specific examination priorities. Correspondent Banking Fourteen years have passed since Congress first identified correspondent banking as a gateway to money laundering into the U.S. Financial System. Since then, institutions of all sizes have been the subject of regulatory enforcement actions, and some institutions have also experienced record-setting penalties and are the subject of Deferred Prosecution Agreements, in many cases, related to activity in their correspondent accounts with foreign financial institutions. This panel will focus on correspondent account risks and trends in the following areas: • De-risking products and customers in correspondent accounts • Risks associated with foreign and domestic correspondents • Affiliate risk and overcoming data sharing obstacles • Correspondent accounts in the brokerage context: the BBH Case • Recent OFAC regulations regarding the opening of correspondent accounts in Cuba AML Technology – Is your institution using the right model? Technology has become a key component of any financial institution’s BSA/AML Program and subject to increased regulatory scrutiny. This panel will discuss the challenges of implementing an effective monitoring system and aligning it with regulatory expectations. Topics include model validation system administration and data integrity De-Risking: The Erosion of the Risk Based Approach The onslaught of new regulations, increased regulatory scrutiny and enforcement actions has led financial institutions to exit certain business lines, geographies and clients. Has the risk-based approach been abandoned and replaced by the “moralization of banking”? AML Global Exchange The international AML landscape continues to present challenges as money laundering schemes, trade-based money laundering, capital flight, tax evasion and sanctions programs evolve and mutate. How are governments and regulators keeping up with developing economic, political and technological events? What are the latest developments on the international regulatory front? International banks must keep aware not only of what is going on in their regions but also what is
taking place around the globe. This panel of bankers, regulators and experts from Latin American, Europe and Asia will discuss legal and regulatory developments in their regions and money laundering activity that they are observing, and discuss how these trends may impact banks in your part of the world. Topics discussed will include the following: • What are the latest trends and developments in international money flows? • How are changes in the Mexican AML regime affecting neighboring countries? • How is the recent series of tax-based prosecutions affecting offshore financial centers? •What are countries doing to update their AML/CTF regimes in preparation for the fourth round of FATF mutual evaluations? U.S. Foreign Corrupt Practices Act (FCPA)/Anti-Bribery and Corruption Global anti-bribery and corruption compliance standards are growing more complex. Banks and their customers operating in Latin America face enhanced anti-bribery and corruption compliance scrutiny from U.S. law enforcement, U.S. business partners and, increasingly, from local regulators. Banks in Latin America – especially those with a U.S. nexus – are expected to develop and implement a risk-based compliance program to mitigate bribery and corruption risk. On the panel, leading practitioners from the U.S., Brazil and Argentina will discuss the rapidly evolving international compliance standards in the anti-bribery and corruption space, and what they mean for banks and their clients. It will also discuss the potential additional compliance challenges posed by the new Brazilian anti-corruption statute. Latest Developments in Trade Based Money Laundering: Geographic Targeting Orders (GTOs), and the Intersection of Fraud and Money Laundering In September 2014, when Homeland Security Investigations (HSI) announced it had uncovered the laundering of massive amounts of narcotics proceeds through Los Angeles’ garment industry, FinCEN responded by issuing a Geographic Targeting Order, imposing additional recordkeeping and reporting obligations on businesses. False documents expose participants in international trade to both fraud and money laundering risks. These hot issues will be addressed by representatives of HSI-Los Angeles and HIS-Miami, a special agent from the Office of the Inspector General at the Export-Import Bank of the United States, a prominent attorney who represents companies and financial institutions engaged in international trade, and the Chairman of the International Bankers Association of California. Caribbean Regulatory Roundtable Virtual Currencies – The Payment System of the Future or the Latest High-Tech Method of Money Laundering? Virtual currencies have been hailed as a more efficient and less
15 thAnnual FIBA AML Compliance Conference Staying Alive: How to Survive the Regulatory Storm
costly method of payment to rival those currently offered by the financial services industry. The Mt. Gox and Silk Road cases have raised the spectre of their use for fraud, money laundering and other criminal activity. The panel will discuss their benefits, risks and future prospects. The Regulatory Evolution in LATAM - Risk Stigma Weighing Over the Region (In Spanish) The 10 SAR/STR Issues – The Year in Review Ask The U.S. Regulators and Policy Makers What questions would you like answered by your federal, functional or local regulators? Learn what’s on your supervisors’ radar and pose your questions in this open, collaborative dialogue. Sanctions Compliance In the aftermath of many high profile cases involving financial institutions this panel will discuss how penalties are applied and what are mitigating and aggravating factors for financial institutions including: • How to minimize risks of sanctions violations • When should you block a transaction, terminate a relationship or look back to review previously processed transactions • The latest sanctions restrictions on Iran, Russia/Ukraine, EU, Canada, Cuba, and anticipated new sanctions for Venezuela, Syria, Libya, Sudan, Myanmar and Africa; when you should submit a voluntary disclosure Personal Responsibility of AML Officers In the past two years we have seen increased attention to issues of personal regulatory and criminal liability for compliance officers. In some recent regulatory actions, compliance officers have been criticized, fined, fired, and even suspended from the industry by regulators. Is this fair accountability or a witch hunt? Will we see compliance officers charged criminally for compliance failures? Come hear current and former white collar prosecutors, defense attorneys, and industry experts debate this topic and describe current trends. If you are a compliance officer working in AML, ABC, or sanctions compliance, this is one panel you do not want to miss! The Culture of Compliance – Do You Have the Right Stuff? In recent months FinCEN and the Office of the Comptroller of the Currency have issued advisories and guidance about the “Culture of Compliance”. This is not a new concept, in fact, the FFIEC Examination Manual addresses this very issue as part of its core examination procedures. Developing a culture of compliance takes time, dedication, and commitment from board members, senior management, and employees at all levels; it requires accountability on compliance related behaviors. This panel will address some of the key elements of the “culture of compliance”:
1. The “tone at the top” per FinCEN Guidance to Financial Institutions 2. Leadership engagement and risk awareness for the first line of defense 3. Information and Communication throughout the Organization 4. Leadership commitment on compliance investment and training Customer Due Diligence and Beneficial Ownership: Regulatory Requirements vs. A Risk-Based Approach? What are financial institutions doing now to meet the regulators’ evolving expectations for Customer Due Diligence, Enhanced Due Diligence and Beneficial Ownership, and what, if anything, are they thinking about doing differently in light of the Treasury Department’s notice of proposed rulemaking and any final CDD rule? This panel will discuss the current approaches that financial institutions are taking to customer risk scoring and how risk scores are being used to determine the appropriate level of due diligence, the frequency of periodic reviews, the measures that can be taken to manage the risks posed by high-risk customers, and the circumstances where a bank may decide that it is just too risky to do business with a customer. The panel also will discuss the proposed CDD rule, any final CDD rule, and the challenges that financial institutions are likely to face in implementing any final rule. Big Issues in Regulatory Exams – How Do You Face Them? How Do You Recover from Them? The Evolution of the Compliance Officer’s Role and the Associated Risks (in Spanish) Lessons to be Learned from Recent Enforcement Actions FATCA & Global Automatic Tax Information Exchange A panel discussion on the latest tax reporting compliance news for those charged with administering and maintaining a FATCA-compliant program as well as an update on ongoing global developments in the area of automatic tax information exchange. Panelists will address: • US FATCA Update: Status of Intergovernmental Agreements (IGAs), Registration and GIINs • Due Diligence Obligations: Documenting pre-existing and new ac count holders in a post-FATCA world • Reporting obligations for 2015: Including new IRS Form 8966, FATCA Report required to be filed by certain FFIs and US •Global Efforts: UK FATCA, Multilateral FATCA Exchange, OECD Common Reporting Standard, a global standard for automatic ex wertgb345change of financial account information The Implications of the Legalization of Marijuana and the Conflict between the FinCEN/DOJ Guidance and Federal Law Nexus of Cyber Fraud & Money Laundering - Eurasian Hacker
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AML TRAINING COVENIENTLY SCHEDULED BEFORE THE CONFRENCE AML/CFT Risk Assessment Certificate & Workshop (In English & Spanish) th
Wednesday, March 4 , 2015 from 9:00am – 5:00pm EST Hyatt Regency Hotel - Miami, Florida
Primary Course Objectives: Develop the risk profile of a financial institution Analyze the characteristics of a corporate customer and assign its risk rating; Identify risks and weaknesses so that internal controls can be put into place to prevent systemic failures that may lead to financial or reputational losses. Highlights: The course is presented in an interactive classroom environment that requires group participation. As a workshop, each group will: Conduct an institutional risk assessment to establish the risk profile of a financial institution Determine the risk classification of a corporate client Conduct a real case study requiring dialogue, analysis, and verbal presentation by the participants. Participants must bring a laptop computer for use during the event. Exam/Certificate of Completion: Participants will be required to deliver a narrative summary of the case study immediately following the training to receive a certificate of course completion. Continuing Education: Approved for 6 continuing education credits for professionals who have earned their FIBA AMLCA or FIBA CPAML Certification
Who Should Attend?
Registration Fees
AML/CFT Compliance personnel Non- FIBA AML Confrence Attendee $595USD Audit personnel FIBA AML Confrence Attendee $495USD Personnel dedicated to private banking and other client services Government $495USD Personnel in the commercial area Regulators/supervisors of financial institutions Banks, broker dealers, and other non-financial institutions.
To register online visit www.fibatraining-register.net. Contact us by phone (305)579-0086 or email fibatraining@fiba.net.
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Easy Ways to Register
1) Phone: (305) 579-0086 2) ONLINE : www.fibaaml.com 3) EMAIL: grace@fiba.net
Continuing Education Credits
Conference Registration Fees: Early bird
Regular Price
FIFA Member & FIBA Alumni (One Attendee)
$1,050 $1,270
FIFA Member & FIBA Alumni (Two to Five Attendees)
$975 $1,200
FIFA Member & FIBA Alumni (Six to Ten Attendees)
$945 $1,150
FIFA Member & FIBA Alumni (Ten or More Attendees)
$895 $1,100
Government
$1,175 $1,350
Banks in Latin America & the Caribbean
$750 $800
• FIBA AMLCA & FIBA CPAML Certifications * • Attorneys for the State of Alabama * • Attorneys for the State of Florida * • Attorneys for the State of Louisiana * • Attorneys for the State of Minnesota * • Attorneys for the State of New York * • Attorneys for the State of North Carolina * • Florida CPA’s * • National Association of State Boards Accountancy * • The Institute of Certified Bankers * *Applied for Florida International Bankers Association (FIBA) is registered with the National Association of State Boards Accountancy (NASBA), as a sponsor of continuing professional education on the National registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN, 37219-2417. Website: www.nasba.org.
* Early Bird discount valid through January 15, 2015 *
Venue Hyatt Regency Miami, 400 South East Second Avenue Miami, Florida, USA, 33131-2197
Hotel Reservations FIBA has reserved a block of rooms for conference delegates at the Hyatt Regency Miami at a preferred rate of $239 per night (not inclusive of the 13% tax), single or double. Please contact the hotel in advance to receive the special rate, be sure to say you are attending the FIBA AML Conference. All rooms are subject to availability. To reserve your room(s) please call the hotel at 1 (888) 421-1442.
Disclaimer FIBA reserves the right, in its sole discretion, to limit or deny access to the conference to any entity or individual. FIBA reserves the right to change or replace speakers and/or presentation topics without notice. Conference participants are not permitted to promote any product, service or event except those expressly approved by FIBA.
www.FIBAAML.com
The Florida International Bankers Association (FIBA), Inc., is a nonprofit trade association founded in 1979. Its membership includes some of the largest financial institutions in the world, including foreign and domestic banks from Europe, the U.S. and Latin America who are active in international trade and finance in our hemisphere. FIBA has been at the forefront in the identification of and provisions of education and training in regards to AML Compliance issues that are particularly applicable to International Financial Institutions who engage in foreign correspondent banking, international private banking and trade financing transactions. These activities require institutions to be cognizant and well informed of the current U.S. and Global Regulatory environment impacting these high risk businesses that are particularly vulnerable to terrorist financing and money laundering. As a leading trade organization focused on international banking and finance, FIBA frequently meets with regulators, submits comment letters and position papers, and is a respected voice in the industry.
(305) 579-0086