Buckley Sandler Webcast: Navigating a Heightened Examination and Enforcement Environment
As federal and state bank regulators continue their comprehensive BSA examinations of regional and super regional banks, a growing number of institutions have found themselves confronted with Orders requiring remediation and/or enhancement of their firm-wide compliance programs. Typically, these Orders require the financial institution to provide an action plan to their regulator within 60 days of the effective date of the Order. At a minimum these Orders require the financial institution to undertake improvements in the following areas:
- Internal controls to ensure compliance by the bank, including all business lines and subsidiaries, with all applicable BSA/AML requirements
- Policies and procedures designed to ensure identification and verification of the identity of account holders in accordance with applicable regulations
- An enhanced independent testing program designed to test for compliance with all applicable BSA/AML requirements
- Management of the BSA/AML program by a qualified chief compliance officer, with requisite authority, who is responsible for implementing and maintaining a program that is commensurate with the organization's size and risk profile
- Clear lines of authority, responsibility, reporting, and independence from the business lines for BSA/AML compliance personnel
- Measures to ensure that BSA/AML compliance functions outsourced by the bank to third parties, including affiliates, are performed to meet regulatory requirements
Please join us as we discuss how to: take proactive steps to avoid such an Order and before an exam, navigate the institutional response to examiners or such Orders including the development of a 60 day action plan, and the operationalization of the plan.
Who Should Attend: This webcast will be of particular interest to in-house legal, compliance, and risk management personnel at banks and other financial services providers.
When: Thursday, March 17, 2016 from 12:00 to 1:00 pm ET
Registration required. Please, no outside law firms, government agency personnel, consulting firms, or media. After registering and being approved, you will receive a confirmation email containing instructions for joining the webcast.
James T. Parkinson focuses on international regulatory compliance counseling, corporate internal investigations, and enforcement defense litigation. He represents clients on a variety of criminal and civil enforcement actions, including Foreign Corrupt Practices Act (FCPA), securities fraud, insider trading, false statements, and environmental matters.