"Implementing an Enterprise-Wide Anti-Money Laundering Program"
SIFMA Anti-Money Laundering and Financial Crimes Conference March 4, 2009 New York, New York Implementing an Enterprise-Wide Anti-Money Laundering Program Introductions Arlene Semaya, Senior Vice President, Compliance Managing Director, JP Morgan Chase John Panagopoulos, Global Head of Investigations and Surveillance, Barclays Capital Alan Williamson, Managing Director, Forensic Services, KPMG, LLP Suzanne Williams, Manager of BSA/AML Risk Section, Division of Banking Supervision and Regulation, FRB 2 Overview of Presentation Key Elements to an Effective Enterprise-Wide AML Program Implementing a Global Enterprise-Wide AML Program Observations from the FRB in Enterprise-Wide AML Programs 3 Written Policies and Governance High Level Policy sets standards Must have basic elements of any AML Program May create an AMLOC, AML Committee oversight Each LOB must develop and implement detailed policies and procedures and controls consistent with Enterprise-wide program 4 Risk Assessments • Firms must identify, assess and quantify the level of risk associated with the Firm’s products, services, customers, transactions and geographic locations. • This is used to develop appropriate policies, procedures and processes to monitor and control the BSA/AML risks. 5 Customer Due Diligence and Information Sharing Enterprise-wide Policy establishing minimum standards Centralized Account Information and Sharing Information 6 Monitoring, Investigations, and Exiting Relationships Monitoring: Vendor Solution or Proprietary Centralized Repository of Investigations Analytics Restricting/Freezing/ Closing Accounts Coordinating Communications 7 Awareness and Training Enterprise-wide Detailed tailored training Delivery Methods Who delivers the message? 8 Implementing a Global Enterprise –Wide AML Program • View from the Center • View from the Edge • View from the Middle 9 Observations from the FRB in Enterprise-Wide AML Programs Supervisory Observations and Challenges in Implementing an AML Program Current International Developments Federal Reserve Board Supervisory Letter 08-8 10 Thank you……to the panellists! 11