Session Key Takeaways Insights On Oversight A Regulatory

Session Key Takeaways

Insights On Oversight: A Regulatory Roundtable on AML Trends and Issues Spencer W. Doak, Director for BSA / AML Policy, Office of the Comptroller of the Currency (OCC) Sarah Green, Senior Director, Enforcement and BSA Policy, Financial Industry Regulatory Authority (FINRA) Christine Ring, CAMS, Managing Director, AML and Compliance Division, Office of the Superintendent of Financial Institutions (OSFI) Andrea Sharrin, Associate Director, Policy Division, Financial Crimes Enforcement Network (Fin. CEN) Rick Small, CAMS, Executive Vice President, Director, Financial Crimes Program, BB&T Suzanne Williams, Deputy Associate Director, Bank Supervision and Regulation, Board of Governors of the Federal Reserve System Moderator: John J. Byrne, Esq. , CAMS

Takeaways A bank’s BSA/AML/CFT department should be viewed as an essential cost-containment center rather than as a cost center and should be recognized as helping to protect the financial integrity of the bank and the U. S. financial system. 3

New York State of Mind: Analyzing the National Implications of NYDFS 504 Monday, September 25 th. 11. 30 am – 12. 45 pm NY State of Mind Section 504 Las Vegas 09 25 2017 11 30 am c

Key Takeaways 1. Clear & documented Policies & Procedures 2. Excellent Project Management with documentation in a secure Repository 3. A well managed Continuous Improvement Program 5

Key Takeaways 4. Robust Independent Testing Ø Is all significant data in the systems? Ø Is it mapped correctly? Ø Are all critical components included in program? Ø Is it risk based? This Rule probably sets new expectations amongst all Regulators 6

The Numbers Game: Developing Quantitative Metrics to Elevate Risk Assessment Accuracy Moderator: Tanya Montoya, Sr. Product Development Manager-Risk, ACAMS Speakers: John F. Caruso, Principal, KPMG Jason Chorlins, CAMS, Principal, Risk Advisory Services, Kaufman Rossin Jason Honeycutt, CAMS-Audit, Senior Vice President, BSA Director, Inter National Bank

Key Takeaways In the near future, at a minimum, institutions will need to: Ø Consider creating a Model Governance Committee, responsible for oversight of the institution’s model risk management program Ø Define an enterprise-wide governance structure that addresses AML models Ø Conduct an AML model inventory and identify the organization’s operational risks Ø Validate and tune the organization’s model and document all efforts on an ongoing basis 8

Is this the year that Sanctions, AML, and Cybersecurity in Correspondent Banking Converge? Sept. 25 | 11: 30 – 12: 45 Vikas Agarwal, Partner, Pw. C Scott Butler, Vice President, Global Financial Crimes Compliance, CIB Treasury Services, JP Morgan Chase Lisa Grigg, Chief Enterprise Financial Crime Compliance Executive, US Bank Moderator: Paul Taylor, Head of Financial Crime Initiatives Americas & UK, SWIFT

Key Takeaways With such rapid change in the FCC realm- geopolitics, cyber and fraud- there is an increased need to be agile and foster collaboration across functions that previously operated independently. Time to remove the silo’s! Find strategies inside the organization to better leverage human intelligence, supporting the shift from transaction monitoring to intention monitoring and better decision making An ever present need to bring together data, and information, and conduct entity analytics and resolution. It is certainly not enough to be technically compliant, above all organizations must be effective 10

Unleashing the Power of KYC Data September 25, 2017 | 11: 30 am Chris K. Mauro Director, Product Management AML Solutions Fiserv

Key Takeaways 1 KYC Collection is an ongoing practice and not restricted just to onboarding 2 The more you know about a customer the more accurately you can monitor them for suspicious activity 3 KYC Data can uncover new revenue opportunities. Use this additional revenue to rationalize your Compliance Business Cases

Securities Small Stocks, Big Issues: Examining Best Practices for Preventing or Investigating Microcap Money Laundering Schemes September 25, 2017 | 12: 45 pm

Key Takeaways § Don’t set it and Forget It § Divide and conquer; make sure it’s clear which department is responsible for each type of review § Document, document! 14

Gaming Spotlight: Best AML Practices to Manage Patron-Related Risks September 25, 2017 | 11: 30 AM – 12: 45 PM Moderator: Vasilios P. Chrisos, CAMS Principal, Financial Crimes Unit Pw. C Speakers: Paul Camacho, CAMS Vice President of AML Compliance Station Casinos LLC Benjamin J. Floyd, CAMS Senior Vice President, AML/OFAC Compliance Officer, Caesars Entertainment Krystal Saab, Esq. Director, AML Compliance Cosmopolitan Las Vegas

Key Takeaways • Due diligence should be reasonable, riskbased and supplemented with sufficient levels of documentation. YOU’RE NOT EXPECTED TO BE THE CRIMINAL INVESTIGATOR! • Reinforce and acknowledge positive behavior exhibited by casino employees. • Risk management is a journey, not a destination. You need to continually tap into all of the internal and external sources of information at your disposal. 16

ACAMS Mystery Theater: A Thriller of a Subject September 25, 2017 | 2: 00 - 3: 15 PM Moderator: John J. Byrne, Esq. , CAMS, Executive Vice President, ACAMS Speakers: Susan J. Galli, CAMS, President, Galli AML Advisory, LLC Daniel D. Soto, CAMS, Chief Compliance Officer, Ally Bank Brian Stoeckert, CAMS, Managing Director, Stratis Advisory

Key Takeawayshoul, d your organization be doing now? § Millennials continue to distance themselves from banks and use alternatives for payments, transfers, and financial management. § Equifax hack increases the likelihood of identity theft and account takeovers with targeted areas for use online and call centers. § Banks and covered financial institutions should consider real estate closing and company formation processes - and the accounts and clients these processes implicate - as risk factors in their CDD, including in client on-boarding, risk-rating and monitoring processes, and including in their beneficial ownership due diligence.

Cyber SAR: Meeting Fin. CEN’s Expectations on Data Collection, Information Sharing and SAR Filing Monday, September 25, 2017 | 2: 00 PM – 3: 15 PM Moderator: Brian W. Vitale, CAMS-Audit, Chief Risk and Compliance Officer / Bank Secrecy Act Officer, Notre Dame Federal Credit Union Speakers: Mauriceo Castanheiro, CAMS, Director of Fraud Analytics, Verafin Vincent Heintz, Managing Director, Head of Controls, Financial Crime Compliance Americas, Standard Chartered Bank Art Taylor, Director, Compliance Operations, Pay. Pal

Key Takeaways • • Digital Identity not synonymous with Digital Footprint Inclusion of key and useful information in SAR filings Cybercrime analysis training for AML and Cyber Teams Financial Intelligence Unit and Cyber Intelligence Unit Collaboration Resources • Financial Services Information Sharing and Analysis Center (FS-ISAC) • FBI Internet Crime Complaint Center (IC 3) • FBI Infra. Gard Chapter (all states) 20

Knowing Your Customer in the Era of Heightened Regulations and Cost Pressures September 25, 2017 | 2: 00 PM – 3: 15 PM Speakers: John Sabatini, Principal, Pw. C Devesh Desai, Principal, Pw. C Vikas Agarwal, Principal, Pw. C Daniel Tannebaum, Principal, Pw. C

Key Takeaways 1 2 3 4 Don’t underestimate the level of effort to comply with the new CDD Rule May 11, 2018 is not the beginning and not the end! Optimize processes and maximize results The cost of non-compliance is always greater

Securities Spotlight: Reviewing Recent Enforcement Actions to Manage AML & ABAC Risks September 25, 2017 | 2 PM-3: 15 PM Moderator Meg Zucker, AML Officer, Royal Bank of Canada Capital Markets Speakers Alessio Evangelista, Deputy Chief, Bank Integrity Unit, US Department of Justice Sarah Green, Senior Director, BSA Policy, Financial Industry Regulatory Authority (FINRA) James Loonam, Of Counsel, Jones Day

Key Takeaways • Build a record of analysis, risks and escalation: “If you didn’t write it down, it didn’t happen. ” But make sure key people are looped in and have the opportunity to manage any material matters that emerge. • Hiring Practices • Just because they worked at a credible Firm in AML does not necessarily mean they have the required skills for your role. Thoughtful interviews ensuring staff is well-met. • References from people who have worked directly with, not simply “know” them. • Kicking the Tires of a program, even if Audit outcome has been Satisfactory: • Review and update rules on an ongoing basis • Be mindful of having different eyes on the same elements the program • Who else besides Audit is looking at your program? 24

Key Takeaways • Risk Assessment • Make them meaningful and don’t just document the assessment but use the information to mitigate risks identified • New Regulations (beyond Policy) • Understand how they might differ in requirements depending on various business models. • Learn from Others • Compare lessons learned from other Firms with your program. • Address potential gaps proactively. 25

Advise and Consent: Managing Internal Processes to Ensure Timely and Appropriate Responses to Enforcement Speakers: Daniel W. Levy, Principal, Mc. Kool Smith Michelle Neufeld, Independent AML Specialist Mark Prater, CAMS-Audit, Vice President, Senior Audit Manager, U. S Bancorp Moderator: Rick Small, CAMS, Executive Vice President, Director, Financial Crimes Program, BB&T

Takeaways Managing Examinations • Ensure the exam team understands your journey - how you got to where you are today and where you are going 27

Takeaways Independent Testing • Rotate staff across broad range of Articles and audit projects • Stay current and relevant • Transparency with management in all things scoperelated • Peer review (also includes Audit Manager) • Additional time to reporting phase • There is but one truth – Partner with other reporting groups to ensure consistency in content and message 28

Takeaways Monitors • A successful relationship with a monitor requires an attitudinal shift that begins before the imposition of the monitorship • Monitorees have called a monitorship an “insurance policy” • The monitor is looking to build a successful compliance program and one that far outlasts the monitorship 29

Model Validation in a World with Rule 504 September 25, 2017| 3: 45 pm – 5 pm Laurence Birnbaum-Sarcy, KPMG Sandra De. Poalo, BNY Mellon Jared Graham, MUFG Union Bank, N. A. Brad Ahrens, Charles Schwab Thomas Keegan, KPMG

Key Takeaways (1/2) • Financial Institutions (including those not subject to Part 504) need to consider impact of 504 on their existing model validation processes and plans • Part 504 requires a strong governance framework around certification process 31

Key Takeaways (2/2) • Understanding and evaluating data used by transaction monitoring and filtering systems is critical to compliance • Regulatory expectations have evolved to expect periodic validation of transaction monitoring, sanctions filtering, and, in some cases, customer risk scoring systems 32

Due Diligence on Your B 2 B Relationships September 25, 2017 | 3: 45 p. m. – 5: 00 p. m. Satish Acharya, Global KYC/AML Practice Lead, Genpact Devesh Desai, Principal, Pw. C Ben Cutler, Sr. Director – SMB Risk Assessment, Lexis. Nexis Risk Solutions Kristen Franks, Solutions Consultant – Anti-Bribery & Corruption Compliance, Lexis. Nexis Risk Solutions Moderator: Jennifer Mc. Entire, Financial Crime Compliance, Lexis. Nexis Risk Solutions

Key Takeaways • Establish a “tone from the top” that is supportive of compliance functions and operations. • Make your documented risk-based due diligence process consistent across all LOB’s. • Utilize toolkits, third parties, and onsite visits to validate information provided by customers. • Integrate advancements in technologies for increased efficiency and effectiveness. • Leverage the information collected in other areas of your business. 34

Las Vegas Case Study: Skimmers, Scammers and Casino Cages September 25, 2017 | 3: 45 – 5: 00 Joseph Gillespie Unit Chief, FBI – Criminal Investigations Jefferson Grace Detective, Las Vegas Metro Police Department Thayne Larson Special Agent, FBI – Las Vegas Field Office James Vaughn Supervisor, Internal Audit – MGM Resorts International

Key takeaways What are the signs to look for with respect to skimmer use? Who is the best contact if you detect unexpected activity? What steps can be taken to assist law enforcement (local/federal)? What are the financial impacts? 36

A Clear and Present Danger: Developing Models to Combat Proliferation Financing September 25, 2017 | 3: 45 PM – 5: 00 PM

Takeaways • Proliferation is a significant global problem • Disrupting proliferation financing disrupts proliferation • North Korea’s likely exposure to the U. S. financial system is greater than generally realized • Critical importance of public-public and public-private partnerships

Seeing SARs: Law Enforcement Weighs in on Recent SAR Aided Investigations September 25, 2017 3: 45 pm-5: 00 pm

Takeaways: • Technology will continue to revolutionize the collection and analyzation of AML investigations. • Better practices in information sharing will result in better investigations. 40

Takeaways: • SAR investigations require public and private collaborations to be successful. • Our partnerships in AML will help defeat partners in crime. 41

AML Best Practices Survey Presentation September 25 th | 5: 10 pm Mark Haddad Head of Corporate Segment Thomson Reuters – Legal

Recap and Final Thoughts… ØDue diligence and AML processes are driven predominantly by internal means ØUltimate Beneficial Ownership continues to pose significant operational challenges ØNotable trends over the last 12 months reinforce the need for department resourcing 43

Racing to the Finish: Homestretch Strategies for Implementing the CDD Final Rule Tuesday, September 26, 2017 9. 45 am – 11. 05 am Speakers Anna M. Rentschler, CAMS Vice President and BSA Officer Central Bancompany Joe Soniat, CAMS-FCI, CFE, BCP Vice President – BSA/AML Officer Union Bank and Trust Megan Hodge, CAMS Executive Compliance Director, BSA/AML Officer Ally Bank Moderator Kieran Beer, CAMS Editor-in-Chief ACAMS moneylaundering. com

Takeaways 1. 2. 3. 4. 5. 6. Don’t wait until the last minute to address them open questions/gray areas Discuss client scenarios with the business, especially for layered/complex entity structures. Supervisory expectations are unclear: stay connected to compliance community & dialogue with examiners. Be sure your processes can be operationalized and sustained over time. Have a way to track the updates to Appendix A (you identified relevant triggers 100 xs this month, did you get the business to confirm ownership in all 100 xs? ) Do some level of oversight testing in the “ICU days” following your golive date to identify failures in the process and get them back on track. 45

The New CTF: Reviewing Practical Tools to Counter Terrorism’s Evolving Financial Methods September 26 | 11: 35 AM – 12: 50 PM

Takeaways • Information sharing is critical to effectively counter terrorist financing and terrorism • Developing terrorist financing typologies requires understanding the threat environment, emerging trends, funding flows and institutional risk, and assessing them in conjunction with each other • Importance of public – private partnerships • Importance of developing proactive and progressive detection mechanisms

Next Generation KYC & KYC Review – Automation of Primary Source Information September 26 th | Tuesday 11: 35 am – 12: 50 Anders A. L. Rodenberg, M. Sc. Bureau van Dijk Head of Financial Institutions and Advisory in North America Anders. Rodenberg@bvdinfo. com Bill Hauserman Bureau van Dijk Senior Director of Compliance Solutions Bill. Hauserman@bvdinfo. com

Key take-aways 1 Automation is needed to break correlation between regulatory demands and cost. And it even increases compliance levels as a bonus. 2 Structured primary source data exists. 3 Automated due diligence based on multiple sources is crucial to detect KYC changes as and when they occur. 4 The Future is waiting and it includes people.

Recruit, Retrain, Retain: Hiring, Developing and Keeping Top AML Talent September 26, 2017 | 11: 35 AM – 12: 50 PM Megan Hodge, CAMS, Executive Compliance Director, BSA/AML Officer, Ally Bank (Moderator) Lauren Kohr, CAMS-FCI, Senior Vice President, Chief Risk Officer Vincent Heintz, Managing Director, Head of Controls, Financial Crime Compliance Americas, Standard Chartered Zachary Miller, CAMS-FCI, Vice President, BSA Officer, Mid Penn Bank

Key Takeaways • Design roles holistically and develop job descriptions that reflect both technical capabilities and the value set to be cultivated in the team • During recruitment, personally engage the candidate & ensure interviews include person depth of the organization, from peers to more senior future colleagues • Strong and sustainable teams reflect broad professional and personal backgrounds, so recruit diversely • Build career entrepreneurship • Cross train to optimize performance and identify the top talent currently in your shop 51

Beneficial Ownership Why the Devil is in the Details September 26, 2017 12: 20 to 12; 50 PM Melaine B. Campbell, Esq. Thomas Cosgrove

KEY TAKEAWAYS Consider asking yourself these questions: • Are we taking all reasonable measures to mitigate the risk by leveraging global data that is accurate, reliable, timely, robust and verifiable? • Does our data bring together corporate linkage and beneficial ownership? • Can we get to this data quickly through modern delivery channels? • Can we leverage analytics to understand direct and indirect relationships, handle looping control and support all end points? • Are we using master data and automated intelligence to create a data inspired compliance program?

Sanctions Update: Keeping Sanctions Management Current and Robust 09. 26. 2017 | 2 pm Session

Key Takeaways • Governance – It is critical to design and utilize a robust governance framework of QA Testing, Mgt. Reporting, and Risk Indicators to ensure management is aware of risk and managing it accordingly • OFAC sanctions on Cuba are constantly evolving. It is important to be aware of the changes that are being made and react accordingly. • The new North Korean Sanction are extraterritorial, and the OFAC sanction have an evaders component as well. • Agility – Regardless of our industry or size of business, it’s critical to think about adaptability and agility when we plan our programs. This is true for watch lists, required controls, intelligence, purchases of new technology. 55

Innovation in Watchlist Screening 26 Sep 17 | 2: 00 pm James Currie, Moderator Andrew Bingenheimer, Speaker Devesh Desai, Speaker Chris Siddons, Speaker Chad Wright, Speaker

Take-Aways Automation & Predictive Analytics can create short term wins Be wary of proposed solutions that exceed practical limitations Data is critical to successful innovation for any level of Machine Learning Strong controls on development and change management go a long way to getting regulators comfortable Technology infrastructure, sound data management and well defined success criteria are critical components 57

The ABCs of FIUs: Building an In-House Financial Intelligence Unit to Bolster AML Careers Session September 26, 2017 2: 00 pm - 3: 15 pm

Moderator Jack Oskvarek, CAMS, CAFP, AMLP Senior Vice President, BSA Executive Director Wintrust Financial Corporation Speakers Lester M. Joseph Senior Vice President Manager, Global Financial Crimes Intelligence Group, Wells Fargo Angel Nguyen, CAMS Vice President Compliance and Financial Crimes Solutions, Enigma William J. Voorhees, CAMS Senior Vice President BSA/AML Financial Intelligence Unit Manager, BB&T 59

KEY TAKEAWAYS 1 2 3 4 Staffing – An FIU must have adequate numbers and skillsets in its staffing. Do not underestimate the power of people and do not overestimate the power of process. Remember that these operations functions depend on oversight and controls Develop a QC/QA group and a Business Unit Self Testing function to ensure controls exist for Internal Audit and exams. Collaboration is key! None of us is as smart as all of us! 60

Budget Stretching 101: Practical Strategies to Help Compliance Dollars Work Overtime September 26, 2017 | 2: 00 PM – 3: 15 PM Moderator: Zach Miller, CAMS-FCI, Vice President / BSA Officer, Mid Penn Bank Speakers: Daniel Eckhart, CAMS, Attorney at Law, Dan Eckhart Law Nancy E. Lake, CAMS-Audit, CAMS-FCI, Director of Compliance Anchor, Atlantic Community Bankers Bank Scott Nathan, Managing Director, Financial Services, Accenture

Key Takeaways • Find, Organize, Calculate, Unite, Seek (FOCUS) • Make everyone part of the AML function • Data analytics changes the interaction model between BSA/AML compliance, regulators, and law enforcement • Balance risk appetite with financial inclusion 62

On High Alert(s): Managing SAR Volume and Risk with Scoring Alerts and SAR Triage September 26, 2017 | 2: 00 -3: 15 Moderator: Alison Jimenez, CAMS, President/ Founder, Dynamic Securities Analytics Speakers: Jim Candelmo, Chief AML Officer, Capital One Jason Frantz, Director of the Financial Intelligence Unit, Discover Bank John Sabatini, Principal, Pw. C

Key Takeaways q Risk Scoring helps differentiate the higher risk “productive” cases from the false positives q This helps facilitates better triaging of case investigations q Also helps better alignment of investigations operations to risk by focusing efforts on higher risk cases, thereby reducing spend on operations q Regulators have recently been receptive to risk scoring with thorough testing, documentation and ongoing validation of the models 64

Assessing the Trends and Protecting Against Domestic Third Party Risk September 26, 2017 | 2: 00 PM Jeff Woods Head of Risk Specialty Sales, Americas Thomson Reuters

Key Takeaways Ø The rise of Domestic terrorism and hate groups in the US is a disturbing trend Ø Ecommerce facilitates the easy funding of terrorism through transaction laundering Ø More and more Americans are becoming involved in the distribution of illicit drugs Ø The traditional compliance model that dedicates more time and resources to International vs. Domestic 3 rd parties is increasingly being challenged and hard questions must be asked about the screening process 66

TBML in the 21 st Century: Time-Tested Strategies to Combat Trade-Based Money Laundering 09. 26. 2017 | 3: 45 pm Session

Key Takeaways • As Trade becomes an increasingly attractive option to money launders, first line stakeholders must be trained on how to detect and escalate TBML. Second line alone is not enough to successfully mitigate TBML activity – engage sales, operations, etc. • Bank Supervisors as well as Industry groups recognize that Trade is different from Cash, and that a tailored approach to TBML controls is therefore necessary. • Beyond record retention obligations, its more critical than ever to retain information and put it to work. Through the use of Big Data, we can identify trends and outliers. Benefits here are magnified through the use of Machine Learning. • Build / buy technology that is agile; you do not know what strategies or typologies will exist in the near / distant future.

Continued Confusion or Clarity? : The Latest on Banking Marijuana Businesses September 26, 2017 | 3: 45 AM – 5: 00 PM Moderator: Lauren Kohr, CAMS-FCI | Senior Vice President, Chief Risk Officer Old Dominion National Bank Speakers: Steve Kemmerling | Founder & CEO, MRB Monitor Tom Fleming, CAMS | Chairman, Link to Banking Matthew Kramer, CAMS | Assistant Vice President, Texas Capital Bank Victor R. Cardona, CAMS | Vice President, BSA, Opus Bank

70

The Future Is Here: Taking Your AML Program to the Next Level with Intelligent Automation September 26| 3: 45 pm – 5 pm Jenny Eliopoulos SVP & Head of Global Anti-Money Laundering Customer Due Diligence (CDD), Northern Trust Company David Kwan General Manager & VP, AML Solutions, NICE Actimize Bill Ward Executive Vice President, Chief BSA/AML and Security Officer, First Republic Bank Donna Weiss (moderator) Director of Product Marketing, NICE Actimize Solutions, NICE Actimize

Key takeaways 1. 2. 3. 4. Set your automation goals and priorities Start small but think big Setting a strong foundation is key Right-size the level of automation to your organization’s size and culture 72

On Balance: AML Veterans on Nurturing Your Career, Your Family – and You AML Careers Session 9/26/17 3: 45 pm – 5: 00 pm

Moderator Jack Oskvarek, CAMS, CAFP, AMLP Senior Vice President, BSA Executive Director Wintrust Financial Corporation Speakers Jason Frantz, CAMS Director of the Financial Intelligence Unit Discover Bank Joanne M. Le. Tourneau, CAMS Executive Director, AML/OFAC Risk Assessment, Global Compliance JPMorgan Chase Markus Schulz Global Head FCC Controls, Group Financial Crime Compliance Standard Chartered 74

Key Takeaways § Be flexible and look for creative solutions to be more efficient § Transparency = creditability = team buy-in = efficiency § Remove obstacles that detract you from the goal § Celebrate the wins! § De-stress by getting organized, walk off stress, eat well for improved mental and physical health, stay fit 75

Life after Law Enforcement (and Other Public Sector Jobs): Transitioning to Private Sector AML Careers Moderator: Will Voorhees, SVP, Manager FIU, BB&T Speakers: Joseph Gallion – SVP, Manager SIU, BB&T Dave Griesbach – AML Experimental Operations Manager, Google Fredrick Reynolds – Managing Director, Global Head of Financial Crime Legal, Barclays Bank

Key Takeaways 1. Upon retirement, be prepared for the 180 degree transition from public service to the banking and/or private sector industry 2. For non-US institutions, understand that not as many people go public to private, so you may need to spend more time on your business case and what you can bring. 3. If possible, start planning for the next career a year out from retirement. 77

Let’s Review: Reviewing Past SARs to Strengthen Future Ones September 26 | 3: 45 -5: 00 Moderator: Chuck Taylor, CAMS, Senior Vice President, & BSA Officer, City National Bank Speakers: Jessica L. Gomel-Veksland, Global Head of AML, Wholesale Banking, HSBC Georgie Kastama, CAMS, BSA Officer, Midfirst Bank Salvatore La. Scala, AML Practice Leader, Managing Director, Global Investigations and Compliance, Navigant Jacqueline Shinfield, Partner, Blake, Cassels & Graydon

Key Takeaways • Prior SARs should be analyzed on a periodic and continuous basis • SAR data should be leveraged when tuning AML rules • An independent view is necessary to optimize the results of the analysis • Process improvement opportunities span multiple areas of the BSA/AML Program • Lookbacks extend to not only SARs, but also to transactions that may not have been suspicious but become so, as a result of new information; • Continuous SAR filing: approach with caution. 79

Disrupting Financial Crime Compliance: Transforming the Approach to Address Risks September 26, 2017 Jim Huvane, Senior Manager Brad Lupton, Senior Manager Kirill Meleshevich, Senior Manager

Key takeaway – Disruption faces challenges, but leads to stronger financial crimes programs Disruption Automation Artificial Intelligence Managed Services Consideration Is it consistent with industry standards and what regulators expect? What if a prohibited transaction gets through or we miss unusual activity? Is the approach proven? Benefit • • 24/7 productivity Double-digit reduction in error rates Data entry costs cut up to 70% Greater insight into unique, new risk factors Customized on-demand Staffing flexibility New technologies, built into existing IT infrastructure Outcome based arrangement 81

Culture Clash: Defending Culture of Compliance Integrity in Sales-Driven Environments September 27, 2017 Moderator: John J. Byrne, Esq. , CAMS, Executive Vice President, ACAMS Speakers: Robert Curry, CAMS, Executive Vice President, Chief Compliance Officer, Risk Management, Key. Bank Daniel D. Soto, CAMS, Chief Compliance Officer, Ally Bank Dan Stipano, Partner, Buckley Sander

Takeaways • A strong compliance culture is an important element in achieving and maintaining regulatory adequacy. • Organizations should review incentive programs to ensure they are not incenting improper behavior. • Complaints Management is an important tool in understanding the results of incentive programs and the effectiveness of an institutions’ overall compliance program. • Strong controls and an independent compliance function are important in helping ensure that violations and unsafe or unsound practices do not occur. 83

What the Hack: Strategies for Managing Growing Cybercrime Risks Date | Time Speaker Jeffrey Tricoli, Cyber Section Chief, Federal Bureau of Investigation DJ Johnson, VP, BSA/AML & OFAC Strategy & Monitoring Charles Schwab William B. Nelson, President & CEO FS-ISAC Moderator Kieran Beer, CAMS, Editor-in-Chief, ACAMS moneylaundering. com

Key Takeaways • • Cyber security is a shared responsibility Training/Education is critical Basic fundamentals are key Focus on both the internal and external