Live Webcast: Following the Money: Financial Crimes Investigations and the Role of the...
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Live Webcast: Following the Money: Financial Crimes Investigations and the Role of the FIU
Transcript of Live Webcast: Following the Money: Financial Crimes Investigations and the Role of the...
Live Webcast:Following the Money: Financial Crimes Investigations and the Role of the FIU
Welcome to Following the Money: Financial Crimes Investigations and the Role of the FIU
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To learn moreacams.org/aml-foundations
A stepping stone for entry-level employees not yet ready for CAMS, and for business line staff, who need solid AML training now so they can add more value on the job today.
To learn more, visit:acams.org/aml-general-awareness
“Oh, no, is it thattime of year again?”
Annual company-wide AML training that satisfies everyone.
You can’t afford to have AML be a “that time of year” perception. You need employees engaged, and management supportive.
JOINING US TODAY
John J. Byrne, CAMSACAMS
Dennis Lormel, CAMSDML Associates
Jim Candelmo, CAMSAlly Financial
Angel Nguyen, CAMSAmerican Express
POLLING QUESTION #1
How many years have you been involved in financial crimes investigations?
0-3 years
3-6 years
> 6 years
Public/Law Enforcement Sector
Private/Financial InstitutionCombination of both
In what area?
• Understanding of the scope and function of FIUs within small, medium and large financial institutions
• Tips for developing efficient, intuitive investigations and how financial institution FIUs should prioritize responsibilities and allocate resources within your investigations group
• Skills to develop an effective on-boarding and ongoing training program for financial investigators
• Analysis of the pros and cons of centralizing the SAR process in institutions of varying size
• A preview of how earning the CAMS-FCI credential will strengthen your institution’s investigative capabilities and certify your investigation skills
WHAT WILL YOU RECEIVE FROM THIS WEBINAR?
The ACAMS Advanced Financial Crimes Investigators Certification program is designedto support and recognize advanced practitioners in financial crimes investigations.ACAMS recognizes that practitioners come from a variety of backgrounds and work indifferent markets and support organizations of every size. Similar to CAMS-Audit, thefirst requirement is that applicants would have to hold the CAMS certification.Additional requirements would entail a mix of experience and training spanning areas offinancial crimes. Examples of the intended target audience are:
Mid-Level Investigators Senior Investigators Law Enforcement Compliance Officers FIU Managers Legal Counsel
WHAT IS CAMS-FCI?
It’s Investigations PLUSEnhancing Your Program Through Data: Building a Financial Intelligence Unit
Strategic Planning: Thinking Bigger Picture
Internal Program and Exam Management
Paying It Forward - Cultivating a Flourishing Investigative Environment that fosters development and retention
Building Relationships with Law Enforcement
IN OTHER WORDS…
WHO IS CAMS-FCI?
− You’ve got a good handle on financial crimes in your field (be it a financial institution or instigative agency)
− You have assisted in gathering documents for internal and external examinations− Maybe you’ve worked with financial institutions gathering information for large
investigations− Perhaps you’ve prepared materials for a Board presentation or two− You’ve wondered what happens to your investigations once you’ve closed them− You’ve said to yourself, “ Self, I love investigations. If I want to advance, I’d have to
leave it behind. I wonder if there is a way to advance and still be involved in investigations?”
CAMS-FCI is YOU!If you’ve answered YES to any of these questions, then…
LIVE PROGRAMCONTENT OUTLINE
• SAR/STR Workshop – Enhancing your data, SAR process, QA/QC
• Legal Process – Understanding law enforcement tools
• Outreach Programs and Communications w/ LE – Building better communication with law enforcement
• Interview Techniques – Information gathering/interacting with business units
• SAR/STR Decision Making – Decision making around the bigger picture
• Quality Assurance – Enhancing SAR program /internal and external exam issues
• Major Case Investigations (Part I & II) – End-to-end investigative case walk through, watch out for curveballs!
• FIU Feedback – Strategic planning/paying it forward
• FIU Build-out and Investigator Onboarding – Building an FIU by cultivating expertise
We want to see you at the next CAMS-FCI program, from November 3 - 5
For full details on the program and eligibility criteria, visit www2.acams.org/advanced
FINANCIAL CRIMES INVESTIGATIONS AND THE ROLE
OF THE FIU“FinCEN’s mission is to safeguard the financial system from illicit use and
combat money laundering and promote national security through the collection, analysis, and dissemination of financial intelligence and strategic
use of financial authorities.”
• Understanding the purpose of what we are doing will continue to lay groundwork and message for what and how a financial intelligence unit (FIU) will work in your financial institution
• Key question: What will be most useful to law enforcement? Build on your investigative foundation
KNOW YOUR FOUNDATION
Conducting Financial Investigations: Four Key Factors
• Investigative mindset
• Investigative process
• Investigative intuition
• Investigative follow-up (vigilance)
INVESTIGATIVE MINDSET
• Do not have a check the box mentality
• Understand crime problems
• Understand how bad guys think
• Understand risk and vulnerability factors
• Reasonableness factor
• Vigilance
POLLING QUESTION #2
Does your financial institution/agency have a Financial Intelligence Unit (FIU) or central intelligence team?
YesNo
FINANCIAL CRIMES INVESTIGATIONS AND THE ROLE OF THE FIU
You know what your foundation is made of, now what?“People will come, Ray. The one constant through all the years, Ray, has been
baseball. America has rolled by like an army of steamrollers. It has been erased like a blackboard, rebuilt and erased again. But baseball has marked the time. This field, this game: it's a part of our past, Ray. It reminds us of all that once was good and it could
be again. Oh... people will come Ray. People will most definitely come.”– Terrance Mann, Field of Dreams (1989)
KNOW YOUR FINANCIAL INSTIUTION
Products
Prioritization
People (size/scale)
MINOR LEAGUE
POLLING QUESTION #3
What is the size of your financial institution?Small (Little League)Medium (Minor League)Large (Major League)
Traditional Bank (checking, savings, debit, credit card)Credit Card/Merchant/Prepaid Issuer Only
Combination – traditional banking and credit/debit/prepaid card issuer
Type of financial institution?
E-bank
KNOW THE PURPOSEOF YOUR FIU
Building Your Field
What is the scope, role and function of the FIU?
Data Gathering
Data Analytics Investigations SAR Writing QA/QC
Monitoring Rule
Development
Exam Management
Geography/ Product
KNOW THE IMPACT THAT YOUR FIU WILL HAVE
Metrics and Reporting: Depending on the scope of your FIU, you will have to respond to different people: various leadership teams (Board of Directors, Risk Committees, Operating Committees), Regulators, Auditors, Business Units, Your Team. Consider what they will expect to see.
Investigation Coordination:Are there other teams that conduct investigations? What type – EDD/KYC, Sanctions/PEP Screening, Ad Hoc Referrals, Subpoenas/NSLs?
Geography:If your organization is global, you will have several considerations: structure of the business and legal entities, how to conduct investigations, additional coordination/communication, processes for account closures
Quality Control/Feedback/Enhancements:Scope will define what your feedback loop will be, both within the FIU and with other internal business units.
How is your FIU structured and organized?
What is your talent profile? Investigators? Managers?
How many people do you need?
How do you ensure you have enough resources?
Does your financial institution require special considerations?
How do you allocate work?
FIELDING THE DREAM TEAM
What is your talent
profile?
Developing / Training Program
Ongoing training and
retention
SPRING TRAINING
It’s never too early to start
spring training!
Definition of RolesPrioritizationQA/QC
Management Reporting
Relationships w/ external
sourcesData
Integration w/ other AML
areas
No SAR Process
Writing
ML TypologiesSAR AudiencesRegulatory Environment
Investigative Procedures
Feedback loop to other areas
of businessFI Structure
HOME PLATE!
Contact us about the next CAMS-FCI program, from November 3 - 5
Contact Geoff Fone for further details about CAMS-FCI at +1 786.871.3021 or [email protected].
