Date: Wednesday, May 15, 2019 | Time: 5:30 p.m. – 8:00 p.m.
Location: Miami Airport Hilton, 5101 Blue Lagoon Drive, Miami, FL 33126
Moderator: Andy Fernandez, Esq. Partner, Holland & Knight
Panelists: Curtis Galera, MBA, LLB, CAMS, CFE, Area Financial Manager, Office of Financial Regulation
Dulce Jerez Bank Examiner, BSA Specialist – CAMS, AMLCA, Office of the Comptroller of the Currency
Daniel Haggerty Principal Examiner, Federal Reserve Bank of Atlanta
(Miami, FL) – On May 15, 2019, the South Florida Banking Institute hosted the ‘Past Presidents Night, Incoming SFBI Board Installation and Regulatory’ panel. As the final SFBI panel of the 2018-2019 calendar year took place, members gathered to introduce and induct the 2020 Board of Directors. The Regulatory Panel consisted of Curtis Galera, MBA, LLB, CAMS, CFE, Area Financial Manager, Office of Financial Regulation, Dulce Jerez, Bank Examiner, BSA Specialist, CAMS, AMLCA, Office of the Comptroller of the Currency, and Daniel Haggerty, Principal Examiner, Federal Reserve Bank of Atlanta. The panel was moderated by previous SFBI President Andy Fernandez, Esq. Partner, Holland & Knight.
One insightful topic of discussion were regulatory exam trends, and how to stay ahead of the curb as a financial institution. Daniel Haggerty provided his insight on the upcoming format for examinations. 60-90 days before the examination takes place, a BSA complexity assessment will now be taking place in order to fully assess the complexity of the institution according to products, services, customers, geography, etc., in order to best delineate and fit the proper personnel in making the best assessment according to the complexity and needs of the institution. Haggerty also added that the FDIC examiners will also now be moving forward in using the term ‘enhanced due diligence’ only when it comes to corresponding banking and banking functions under very specific circumstances.
Dulce Jerez spoke on the implementation of the May 2018 FDIC Beneficial Practices and Procedures, and how the internal audit department made this one of their most positively impacted priorities. As a result, financial institutions have been including this inside of their risk assessments. Jerez also noted that there has been an increasing number of transactions related to cryptocurrency and virtual currency, and BSA officers have been getting better at identifying these risks.
Curtis Galera and Daniel Haggerty concluded the night with a topic of growing interest-the hemp and CBD oil trade. As a result of the 2018 Farm Bill, anything that exceeds 0.3% THC remains a Schedule I controlled substance. Banks should consider these issues when performing due diligence on any customer that is involved in transactions involving CBD and Hemp. Having zero tolerance for THC with 0.3% tolerance can provide some protection against the most serious, drug-related and financial complications.