Date: May 16th, 2018
Location: Miami Airport Hilton
Moderator: Andres Fernandez
Speakers: Daniel Haggerty: The Federal Reserve Bank of Atlanta, Miami Branch
Efrain Martinez: The Office of the Comptroller of the Currency (OCC)
Curtis Galera: The Florida Office of Financial Regulation
Tim Maykut: The Federal Deposit Insurance Corp., RMS – Examiner
(Miami, FL)- On May 16th, 2018, South Florida Banking Institute hosted the annual ‘Past President and BSA/AML Regulator’ panel. Since 1950, South Florida Banking Institute has provided education, research and networking opportunities for bankers in South Florida. As part of the final panel of SFBIs’ 2017-2018 term, a portion of the panel was dedicated to recognizing the SFBI Board of Directors and Officers. Awards of outstanding leadership were given to honor exiting members, Luis Santiago and Andres Fernandez. Luis Santiago dedicated his time, serving as Director of the SFBI Board, 2009-2018. Andres Fernandez was also awarded, having served as President through 2017-2018.
As the panel continued, Guillermo Benites was introduced as President for the 2018-2019 term. Moderator Andres Fernandez led the conversation touching base on the topic of BSA/AML Regulation with this months’ speakers: Daniel Haggerty of The Federal Reserve Bank of Atlanta-Miami Branch, Efrain Martinez of The Office of the Comptroller of the Currency (OCC), Curtis Galera of The Florida Office of Financial Regulation, and Tim Maykut of The Federal Deposit Insurance Corp., RMS – Examiner.
As stated by the FDIC, “Bank Secrecy Act Examination Program Overview –
“The FDIC has prescribed in its regulations, Section 326, Subpart B – Procedures for Monitoring Bank Secrecy Act Compliance (12 CFR § 326.8) a requirement that depository institutions establish and maintain procedures reasonably designed to assure and monitor the compliance with the BSA and the implementing regulations 31 CFR Part 103. The FDIC monitors compliance with the BSA-related regulations by conducting on-site examinations of every FDIC-supervised depository institution.
BSA compliance is a safety and soundness issue due to the reputational, regulatory, legal, and financial risk exposure to a bank involved in money laundering schemes or willfully violating the BSA statute. Civil money penalties and regulatory enforcement actions may be imposed for noncompliance with money laundering regulations which can endanger the bank’s capital and earnings. Furthermore, banks may be criminally prosecuted for willful violations of money laundering statutes that could ultimately lead to termination of FDIC insurance.”
Guest speakers provided guidance towards understanding expectations regarding the BSA/AML compliance structure, for example dissecting The FinCEN Suspicious Activity Report (SAR) form procedures, such as triggers, customer due diligence, fraud, and cybersecurity guidance requirements. All speakers were in agreement at the notion of properly seeking guidance through the governing structure, and documenting your procedures to make sure your financial institutions are in compliance.
The Tradition Continues…