Recently, FinCEN issued a Notice of Proposed Rulemaking (Proposed Rule) “Confidentiality of Suspicious Activity Reports”. This proposed rule seeks to broaden the definition of confidentiality as it pertains to SARS by clarifying the statutory prohibition against the disclosure of an individual’s SAR by a financial firm in an attempt to avoid compromising the investigation. This new guidance will affect banks, financial institutions, and broker dealers significantly by clarifying some of these important issues:
- When can the existence of a SAR be shared
- What to do with the supporting documentation of a SAR and can this be revealed
- Disclosure by Federal Authorities
- Safe harbor provisions
- Technical amendments
- Implementation Issues
The Knowledge Group is assembling a panel of distinguished professionals and thought leaders to help understand the new guidance and its impact on your institution and the broader market. The speakers will present their expert opinions in a two-hour LIVE webcast. Attending this webcast will give you a sound foundation on the ins and outs of the new guidance. Join this esteemed group of experts and you will be in the know with respect to this important regulatory change.
Course Level: Intermediate
Prerequisite: None
Method Of Presentation: Group-Based-Internet
Developer: The Knowledge Conference
Recommended CLE/CPE Hours: 2.0
Important Note: Your State Bar or Accounting Board will make the final determination with respect to continuing education credit. If you are applying for CLE credit in Texas you must register 20 days before the event date or you will not be able to obtain CLE credit.
Advance Preparation: Print and review course materials
Course Code: 093935
Frederick E. Curry III
Principal Forensic & Dispute Services
Carol R. Van Cleef
Partner
Andras Teleki
Partner
Frederick E. Curry III, Principal Forensic & Dispute Services, Deloitte Financial Advisory Services LLP
What to expect in upcoming AML examinations and how to avoid common pitfalls. Specific focus will be given to:
- Maintaining the four program pillars
- Transaction monitoring and suspicious activity investigations
- Illegal Internet Gaming
- Compliance with Special Measures
- Other emerging examination trends
Andras Teleki, Partner, K&L Gates LLP
- Brief overview of the Etrade SAR settlement with FINRA;
- Brief overview of the Scottrade SAR settlement with FINRA;
- Discuss differences between monitoring for market manipulation/securities fraud and for money laundering;
- Discuss what Etrade and Scottrade mean for AML compliance in the securities business;
- Discuss development of AML policies and procedures post Etrade and Scottrade;
- Discuss special considerations in analyzing whether potential market manipulation/securities fraud requires a SAR filing; and
- Overview of what one can expect with SAR filings going forward.
Carol R. Van Cleef, Partner, Patton Boggs LLP
** Speaker Agenda to be added soon.. **
- AML/BSA Compliance Officer
- Money Laundering Reporting Officers
- Money Service Businesses
- Bank & Financial Institutions Auditors
- Banking Lawyers & Consultants
- Bank Auditors
- Investment Advisers
- Broker-Dealers
- Investment Companies
This is a must attend event for anyone interested in Confidentiality of Suspicious Activity Reports
- New guidance explained by the most qualified key leaders & experts
- Interact directly with panel during Q&A