| Day 1 |
8:30 AN to 4:30 PM |
Foundations of AML and Leadership Responsibilities
Build AML knowledge and clarify leadership roles in audit/exam preparedness.
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| I. Enhanced BSA & AML Knowledge |
- Money laundering stages and typologies (FFIEC: Overview, p. 2-3).
- Role of the Bank Secrecy Act (BSA) and why it matters to leaders.
- Interactive Q&A: How AML failures impact banks and leaders personally
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| II. International; Regional, and USA’s Federal Regulatory Framework |
- FATF, APG and other international/regional bodies and framwork
- U.S. BSA requirements (31 CFR Chapter X) and FFIEC guidance.
- AML program pillars per FFIEC Manual
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- Leadership accountability: Regulatory expectations for oversight.
- Group: Real-world penalties for banks/leaders (e.g., fines, reputational risk).
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| III. Risk-based Approach (RBA) |
- FFIEC’s risk assessment principles (FFIEC Manual)
- How leaders identify risks in their areas (e.g.: transactions, high-risk clients).
- Case Study: A branch manager assesses risk in a busy urban location
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| IV. Leadership in Audits/Examinations |
- FFIEC objectives: Compliance, weakness identification, corrective action (FFIEC Manual.)
- Leaders’ role: Preparing staff, ensuring controls, responding to examiners.
- Activity: Map out a branch’s AML responsibilities and audit touchpoints.
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| V. Takeaways |
- Leaders gain AML basics, regulatory context, and their role in audit readiness.
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| Day 2 |
8:30 AM to 4:30 PM |
Internal Controls and Preparing for Audits/Examinations:
Equip leaders to strengthen controls and prepare for scrutiny, alongside planning basics.
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| VIII. Internal Controls Before the Examination |
- FFIEC on controls: Policies, procedures, systems for BSA compliance (FFIEC Manual)
- Leadership actions: Training staff, monitoring transactions, documenting processes.
- Pre-audit prep: Self-audits, control testing, fixing gaps
- Exercise: Review a branch’s control checklist and recommend improvements.
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| IX. Responding to Law Enforcement Requests – Part 1 |
- Basics of BSA and PATRIOT Act Section 314(a) obligations (FFIEC Manual, p. 68-70).
- Leaders’ role: Ensuring staff know how to flag requests, coordinating with BSA officers.
- Practical tips: Verify requests, maintain confidentiality, escalate appropriately.
- Role-Play: A branch manager receives a subpoena and responds
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| X. Examination Planning Process |
- FFIEC planning: Review reports, assess risk, define scope (FFIEC Manual)
- Leaders’ prep: Providing data, briefing staff, aligning with auditors/examiners.
- Quiz: Match planning steps to leadership responsibilities
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| XI. Risk Assessment for Scoping |
- FFIEC risk factors: Transactions, products, geography (FFIEC Manual)
- How leaders’ control strength shapes audit scope.
- Exercise: Scope an audit for a branch with weak controls.s
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| XII. Engaging Stakeholders |
- FFIEC on coordination with management (FFIEC Manual, p. 12).
- Leaders’ role: Answering examiners confidently, protecting the bank.
- Role-Play: A department head briefs an examiner on branch controls.
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| XIII. Takeaway |
- Leaders learn to bolster controls, handle LEA requests, and prepare for audits/exams
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| DAY 3 |
8:30 AM to 4:30 PM |
Conducting the Examination/Audit – Fieldwork Skills
Teach fieldwork skills and how leaders support and respond during audits.
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| Morning Section: Commute to New York; Hereunder are for Afternoon Section |
| I. Testing Methodologies |
- FFIEC procedures: Validate CDD, monitoring, SARs (FFIEC Manual)
- Leaders’ role: Ensuring staff follow controls, providing records.
- Group: Test a branch’s CDD file and explain findings to an examiner.
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| II.Transaction Testing and Data Analysis |
- FFIEC on transaction reviews (FFIEC Manual).
- Leaders’ prep: Monitoring for red flags (e.g., structuring), training tellers.
- Exercise: Analyze branch transactions and justify to an auditor.
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| III.Interviews and Observations |
- FFIEC on staff interviews (FFIEC Manual).
- Leaders’ response: Preparing staff, explaining processes clearly.
- Role-Play: A branch manager answers an examiner’s questions on SARs.
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| IV. Takeaway |
- Leaders support fieldwork and respond effectively to protect their areas
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| Day 4 |
8:30 AM to 4:30 PM |
Evaluating Results, Reporting, and Responding to Law Enforcement
Assess programs, report findings, and deepen LEA response skills for all roles.
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| I. Evaluating AML Program Effectiveness |
- FFIEC criteria: Control adequacy, systemic issues (FFIEC Manual).
- Leaders’ lens: Identifying branch-level weaknesses, preparing fixes.
- Case Study: A department head evaluates a flawed program.
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| II. Responding to Law Enforcement Requests – Part 2 |
- Advanced scenarios: Subpoenas, NSLs, 314(a) requests (FFIEC Manual)
- Leaders’ duties: Timely data provision, avoiding “tipping off,” escalation protocols.
- Exercise: Draft a response to a mock 314(a) request from FinCEN.
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| III.Writing the Report |
- FFIEC report structure: Summary, findings, actions (FFIEC Manual).
- Leaders’ input: Explaining branch context, defending good faith efforts.
- Exercise: Draft a report section with a control gap and LEA response note.
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| IV. Communicating with Stakeholders |
- FFIEC on exit meetings (FFIEC Manual)
- Leaders’ strategy: Answering examiners confidently, protecting reputation.
- Role-Play: A branch manager presents to a regulator, addressing a finding.
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| V. Emerging Risks and International, Regional; US’s Federal Priorities |
- FinCEN focus: Crypto, trafficking, cybercrime.
- Leaders’ prep: Updating controls, training for new risks.
- Discussion: Adapting to LEA and audit trends.
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| VI. Takeaway |
- Leaders assess controls, handle LEA requests, and communicate effectively.
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| DAY 5 |
8:30 AM to 4:30 PM |
Capstone Exercise and Wrap-Up
Apply skills in a mock scenario, emphasizing leadership preparedness and response
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| I. Capstone Exercise – Mock Examination |
- Scenario: Audit a bank branch, assess controls, and respond to an LEA request.
- Tasks: Review controls, test (e.g., SARs, CDD), analyze data, handle a 314(a) request, draft findings.
- Teams: Mixed groups (auditors, leaders) with materials (e.g., policies, LEA subpoena).
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| II. Capstone Presentations |
- Teams present findings, control fixes, and LEA response, per FFIEC standards..
- Leaders defend their branch’s efforts to “examiners” (peers/instructor). .
- Feedback: Focus on clarity and protection strategies
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| III. Remediation and Follow-Up |
- FFIEC on corrective actions (FFIEC Manual).
- Leaders’ role: Implementing fixes, training staff, improving LEA processes
- Case Study: Branch remediation after an audit and LEA request.
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| IV. Course Wrap-Up |
- Recap: Controls, LEA responses, audit prep, and leadership strategies.
- Q&A: How leaders protect themselves and their banks.
- Evaluation: Feedback form and certificate distribution.
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| V. Takeaway |
- Leaders and auditors apply skills to control, prepare, and respond effectively
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| Site visit and experience sharing from a US banks or money transmitter’s head office/agents |