Pinpointing the crucial instances of the autophagy phenomenon
Knowing Your Customers: Pinpointing Patterns for Increased Vigilance
-
Upload
jay-postma -
Category
Law
-
view
166 -
download
0
description
Transcript of Knowing Your Customers: Pinpointing Patterns for Increased Vigilance
![Page 1: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/1.jpg)
Knowing Your Customers:
Pinpointing Patterns for
Increased Vigilance
1
![Page 2: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/2.jpg)
Objectives
2
Enhance risk management practices to better mitigate risks
Protect business and make it more profitable
Protect and serve your community – be a good citizen
![Page 3: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/3.jpg)
Suspicious Activity
• Prevent• Detect• Report• Assist
3
![Page 4: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/4.jpg)
Culture of Compliance
Signs of a lax, Non-Compliance Culture?
FinCEN’s Culture guidance – FIN-2014-A007Advisory to U.S. Financial Institutions on Promoting a Culture of ComplianceEngaged LeadershipCompliance not compromised by revenue interestsAppropriate internal information sharingAdequate Human and Technological ResourcesEffective Program- Independent, Competent TestingUnderstand importance, utility of reporting
4
![Page 5: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/5.jpg)
Sea Change“As Director, I feel it is important that financial institutions take responsibility when their actions violate the BSA. And by accepting responsibility, it is not just about admitting to the facts alleged in FinCEN’s enforcement action. It is also about admitting a violation of the law. Over the last year, we have changed our practice at FinCEN to one in which our presumption is that a settlement of an enforcement action will include an admission to the facts, as well as the violation of law. And, we have begun implementing this practice in our enforcement actions against all sizes and types of financial institutions.
Integrity and transparency goes a long way. It is a great bestowal of trust that enables financial institutions to be part of the U.S. financial system, to be part of the global financial system. And that trust -- that privilege -- comes with obligations. One of those obligations is a responsibility to put effective AML controls in place so criminals and terrorists are not able to operate with impunity in the U.S. financial system.
As FinCEN’s recent enforcement actions show, FinCEN will act under such circumstances to protect the integrity and transparency of the U.S. financial system.”
Jennifer Shasky Calvery, Director, FinCEN
FIBA, Anti-Money Laundering Conference
February 20, 20145
![Page 6: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/6.jpg)
Hard Target OR Soft
Pushover
• Do not compromise yourself• with exceptions• poor documentation• lack of focus or willpower
• Will you be a wet noodle? Man or Mouse?
• Official government ID - real, current• not expired• not international driver’s licenses• not “for novelty purpose only” ID
cards
6
![Page 7: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/7.jpg)
Customer Identification Program• Establishing a reasonable basis to believe person is
who he/she claims to be• Mickey Mouse? Elvis Presley? (I think not….)
7
![Page 8: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/8.jpg)
What does KYC look like?
• Before you can Know Your Customer, you need to know your market.
• How do I recognize a customer when I see him/her?
• How do I distinguish a person coming in to buy something that I don’t want to be a “customer”?
8
![Page 9: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/9.jpg)
Solid Understanding of Market
9
![Page 10: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/10.jpg)
What is normal & expected?
Socio - Economic profile
occupation
education
income
ethnicity
dress
speech patterns
10
![Page 11: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/11.jpg)
• Socio-pathic profile
• prevalent problems and issues in our
neighborhood
• familiarity with types of people who may be
perpetrating crimes in our neighborhood
• familiarity with types of victims locally
• Who is being taken advantage of in our
community?
11
What is normal & expected?
![Page 12: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/12.jpg)
Good Customer Interface
12
![Page 13: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/13.jpg)
STOP!
• Don’t be distracted
• Make eye contact
• Pay attention
• Be alert
13
![Page 14: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/14.jpg)
• Be observant
• Really look (not just see)
• Observe demeanor
• Detect signs of deception14
![Page 15: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/15.jpg)
Listen• Clear questions and answers
• non-threatening
• casual alertness
15
![Page 16: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/16.jpg)
Who is this person?• Be friendly- you want customers to come back• Details- employment, occupation, title, where• other identifiers• does person actually live/work nearby?• family, friends, business associates, related
customers• What might that tell us?
16
![Page 17: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/17.jpg)
What services?• Used, inquired about
• Cross selling is good business practice
• helps understand customer too
• may also help identify red flags
• Does person meet profile of what is expected for market?
• Does timing, frequency of transactions make sense?
17
![Page 18: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/18.jpg)
Levels of Knowing• New customer – simple remittance• Repeat remittance customer• Detailed information gathered from multiple tranx
types• No interaction• Moderate interaction• Closely held, limited openness• Too open
18
![Page 19: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/19.jpg)
Training - OngoingTraining –
• not just once a year
• can’t set it and forget it
• do risk based refreshers
throughout year
19
![Page 20: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/20.jpg)
Role PlayingIsn’t role playing just another way of…
• inspect what you expect?• Allows you to demonstrate how to handle real life
scenarios effectively• Mystery shopping can help prove whether training
is effective or not
20
![Page 21: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/21.jpg)
21
Fraud
![Page 22: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/22.jpg)
22
Elder Abuse
![Page 23: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/23.jpg)
23
Human Trafficking
![Page 24: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/24.jpg)
24
Drug Trafficking
![Page 25: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/25.jpg)
25
Terrorist Financing
![Page 26: Knowing Your Customers: Pinpointing Patterns for Increased Vigilance](https://reader036.fdocuments.us/reader036/viewer/2022062706/557c7e15d8b42a37278b4b22/html5/thumbnails/26.jpg)
Jay Postma, CAMSPresidentMSB Compliance [email protected]
John Schmarkey, CAMS, CFEBSA/AML Compliance [email protected]
26
www.MSBComplianceInc.com
www.Twitter.com/MSBCompliance
Weekly newsletter: www.paper.MSBComplianceInc.com