FinCrimes Webinar Series Recap: The Role of Corruption Risk in a Financial Crimes Compliance Program

BuckleySandler hosted a webinar, The Role of Corruption Risk in a Financial Crimes Compliance Program: What are Banks Doing to Detect Corruption in the Wake of the FIFA Scandal?, on September 24, 2015 as part of their ongoing FinCrimes Webinar Series. Panelists included Thomas Coupe, EMEA Global Financial Crimes at Bank of America Merrill Lynch; and Compliance; Gaon Hart, Global Anti-Bribery & Corruption Policy and Education Lead at HSBC; and Denisse Rudich, Financial Crimes Compliance Specialist at Firedrake Consulting. The following is a summary of the guided conversation moderated by Jamie Parkinson, partner at BuckleySandler, and key take-aways you can implement in your company.

Best Practice Tips and Take-Aways:

  1. Corruption risk for a financial services firm is presented both directly and indirectly. Corruption risk is presented directly when an employee or third parties acting on behalf of an institution act in a way that implicated anti-corruption laws, such as the Foreign Corrupt Practices Act, U.K. Bribery Act or another anti-corruption law. Corruption risk is presented indirectly when a customer seeks to use a financial institution for a corrupt deal or to hold or transmit funds associated with a corrupt scheme.
  2. It is important to have one person your organization can look to when an anti-corruption concern arises. This person should serve as the point of contact for your regulators and have the ability to quickly escalate concerns to senior management and the board of directors.
  3. New customers with past corruption issues present special challenges. Be sure that your onboarding and due diligence processes are able to identify and evaluate these concerns.
  4. Bear in mind that corruption risk management also requires looking at your organization internally. This means examining your own employees for conflicts issues, evaluating your organization’s sponsorships and donations, and performing due diligence on your third-party suppliers.
  5. Effective anti-corruption risk management requires cultivating a culture within your organization that supports your efforts. This is an area that regulators are increasingly interested in.

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BuckleySandler Webinar Recap: Strategies for Meeting the CFPB’s Expectations for Consumer Complaint Management

On September 29, BuckleySandler hosted a webinar, “Meeting the CFPB’s Expectations for Consumer Complaint Management,” presented by partner Jonice Gray Tucker, counsel Lori Sommerfield, and counsel Kari Hall. This recap covers highlights from their discussion, which included a discussion of the CFPB’s expectations and practical advice for managing consumer complaints in the evolving regulatory environment.

Background

The webinar began with a brief background on the CFPB’s approach to consumer complaints. In particular, the presenters touched upon how the CFPB has used complaints as a driving force in determining priorities in guiding supervisory work, identifying leads for enforcement, and in informing rulemaking efforts. The presenters also discussed how the Bureau may deal with deficiencies in consumer complaint management in examinations and ways in which the outgrowth of such deficiencies may lead to enforcement actions. In addition, the presenters highlighted key elements of effective complaint management programs. Read more…

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BuckleySandler Hosts Webinar on TRID for Investors

On September 15, BuckleySandler hosted a webinar, “TRID for Investors” presented by BuckleySandler partner Benjamin Olson and associate Brandy Hood. The webinar addressed what purchasers of mortgage loans need to know about the TILA-RESPA Integrated Disclosure rule (TRID rule) that goes live on October 3, 2015. Specifically, Mr.Olson and Ms. Hood addressed evolving assignee liability, identifying risks, correcting errors, and identifying apparent errors. They also discussed ambiguous liabilities and common misconceptions, and focused on information that will help investors develop instructions and procedures that reduce litigation risk without unnecessarily limiting the pool of loans meeting those standards. For additional information and resources on the TRID rule, please visit our TRID Resource Center.

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BuckleySandler FinCrimes Webinar Series Recap: Best Practices in Customer Due Diligence and Know-Your-Customer

BuckleySandler hosted a webinar, Best Practices in Customer Due Diligence and Know-Your-Customer, on May 21, 2015 as part of their ongoing FinCrimes Webinar Series. Panelists included Eric Arciniega, Senior Manager, BSA/AML Due Diligence Operations at First Republic Bank; Janice Mandac, Global Head of KYC at Goldman Sachs; and Nagib Touma, Director Global AML/KYC at Citi. The following is a summary of the guided conversation moderated by Jamie Parkinson, partner at BuckleySandler LLP, and key take-aways you can implement in your company.

Best Practice Tips and Take-Aways:

  1. Establishing company-wide/global standards for your company’s customer due diligence and KYC program will help to ensure consistency throughout the organization. But, for global institutions, you must also be able to accommodate jurisdictions with requirements that are more stringent than the global standards.
  2. Be aware of data privacy standards in the countries where you operate. These standards pose a particular challenge to operating a centralized customer due diligence and KYC program.
  3. Regulators’ recent focus on model risk management extends to your customer risk rating model. Ensure that your model is being tested and tuned rigorously.

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FinCrimes Webinar Series Recap: Conducting an Effective Financial Crimes-Related Internal Investigation

BuckleySandler hosted a webinar, Conducting an Effective Financial Crimes-Related Internal Investigation, on April 23, 2015 as part of their ongoing FinCrimes Webinar Series.  Panelists included John Mackessy, Anti-Money Laundering & Trade Sanctions Officer at MasterCard and Saverio Mirarchi, Senior Director at Treliant Risk Advisors and former Chief Compliance and Ethics Officer at Northern Trust.  The following is a summary of the guided conversation moderated by Jamie Parkinson, partner at BuckleySandler, and key take-aways you can implement in your company. To request a recording of this webinar, please email Nicole Steckman at nsteckman@buckleysandler.com.

Key Tips and Take-Aways:

  1. Make sure that the organization has appropriate policies and procedures in place to quickly and efficiently react when an investigation begins.
  1. Have systems in place to quickly identify the veracity of any allegations and be prepared to begin the internal investigation as soon as possible.
  1. Be prepared for, and understand the impact of having, a compliance monitor as part of any settlement agreement.

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