BSACS Certification Training Orientation

Monday, July 10, 2023
10:30-11:45 a.m. CT

Speakers
- Melisa Kallestad
- Colleen Kelly
- Valerie Moss
- Isaida Woo

This session is designed for first-time attendees and anyone taking the BSACS (Bank Secrecy Act Compliance Specialist) certification exam.  We’ll utilize this time to acclimate this group of attendees to the eSchool and certification process.   Additionally, attendees will have an opportunity to meet CUNA and NASCUS staff.

Learning objectives:

• Learn how to make the most of your learning experience
• Meet CUNA and NASCUS staff and your peers
• List steps to certification
• Learn about the certification exam and other BSA/AML/CFT resources

BSA 101 and Compliance Specialist (BSACS) Certification Class (70 mins.)

Tuesday, July 11, 2023
On-demand

Speakers
- Colleen Kelly
- Valerie Moss

The curriculum of this session encompasses crucial Bank Secrecy Act (BSA) and Anti-money Laundering (AML) content for students who need a comprehensive understanding of this area.  The class is taught by experienced industry experts Colleen Kelly, CUNA senior federal compliance counsel, and Valerie Moss, CUNA senior director of compliance analysis.  The content is designed for credit union professionals who need to learn BSA and AML requirements, as well as anyone interested in refreshing their foundational knowledge in this area.  This 70-minute on-demand class is available to registered attendees beginning July 11, 2023.   

Topics include:

• Components of a BSA compliance program, including member due diligence
• Customer/Member Identification Program (CIP/MIP)
• Currency Transaction Reports (CTRs)
• Suspicious Activity Reports (SARs) and monitoring requirements
• Responding to law enforcement requests
• BSA recordkeeping requirements
• 314(a) and 314(b) Information Sharing
• Office of Foreign Assets Control (OFAC) compliance

BSACS Certification Exam Study Hall

Friday, August 4, 2023
10:30 – 11:30 a.m. CT

Speakers
- Melisa Kallestad
- Colleen Kelly
- Valerie Moss

Designed for students taking the CUNA Bank Secrecy Act Compliance Specialist (BSACS) Certification Exam, this session is facilitated by industry experts Colleen Kelly, CUNA senior federal compliance counsel, and Valerie Moss, CUNA senior director of compliance analysis.   This 60-minute, question-and-answer format session is designed to help students prepare for the exam. 

Students should sufficiently prepare for the exam prior to this study hall session by studying the content of the “BSA 101 and Compliance Specialist (BSACS) Certification Class” and the “CUNA BSA 101 Compliance Guide.”  Students are encouraged to email their questions before the session to cucomply@cuna.com, Subject: BSA 101 Study Hall, or come to the session prepared to ask any questions they have about the material.  This study hall session will NOT be a prepared review of the specific exam content.

Take BSACS Certification Exam

Monday, August 7, 2023 (Exam window opens on this date)

Passing the BSACS (Bank Secrecy Act Compliance Specialist) certification examination is one of two requirements of earning the BSACS designation.   The second requirement is attendance to CUNA BSA/AML Certification eSchool with NASCUS, specifically all Level 101, 201 and general sessions.  Students are only tested on Level 101 content (i. e. “BSA 101 and Compliance Specialist (BSACS) Certification Class”).  Students are allotted two hours to complete the examination.   The closed-book exam is delivered online, requires a proctor, contains 40 multiple-choice questions, and requires a passing score of 70%.

To prepare for the exam, students should:

• Attend “BSACS Certification Training Orientation” (75 mins.)
• View and study the content of “BSA 101 and Compliance Specialist (BSACS) Certification Class” (70 mins.)
• Utilize the “CUNA BSA 101 Compliance Guide” as an additional learning resource.

Navigating CIP Challenges: FAQs
On-demand (20 mins.)

Speaker: Colleen Kelly

Credit unions are required to have a Board-approved Customer Identification Program (CIP) as part of its BSA/AML/CFT Compliance Program. While the regulatory requirements appear straight forward – collect and verify four pieces of identifying information – when it comes to operational compliance there is a lot of gray area to navigate.  In this session, attendees will be presented with several scenarios, given time to consider possible solutions, and review relevant FinCEN guidance to identify the best responses.    

Learning Objectives:

• Explore options for collecting and verifying required identifying information when a member does not have a SSN or street address.
• Review guidance on how to apply the regulatory requirements to various accounts, such as trust accounts, escrow accounts, existing accounts, joint accounts and loan applications.
• Learn how to apply CIP requirements to account relationships such as Power of Attorney and indirect lending.

To Report or Not to Report – A Closer Look at Cash Transactions & CTRs
On-demand (33 mins.)

Speaker: Colleen Kelly

Credit unions must report all currency transactions over $10,000, whether the transaction is suspicious or not.  This session builds on the information provided in the BSA 101 session to look at more challenging CTR reporting scenarios, such as structuring, aggregation and business accounts.

Learning objectives:

• Review the 4 parts of the Currency Transaction Report (CTR)
• Explore structuring examples and when to aggregate transactions
• Consider examiners’ expectations regarding policies, procedures and processing for preparing, filing and retaining CTRs

Suspicious Activity Monitoring, Reporting and Follow-up Requests from Law Enforcement
On-demand (32 mins.)

Speaker: Valerie Moss

Suspicious activity monitoring and reporting are critical internal controls. Proper monitoring and reporting processes are essential to ensuring that the credit union has an adequate and effective BSA/AML/CFT compliance program. Credit unions must also have policies, procedures, and processes in place to respond to follow-up inquiries and requests for information from law enforcement agencies.

Learning Objectives:

• Find out what policies, procedures and processes credit unions should have in place for managing alerts of unusual activity, identifying reportable suspicious activity, and filing SARs.
• Learn how to address continuing suspicious activity and repeat SAR filings.
• Explore how to handle law enforcement requests for SAR supporting documentation, and requests that go beyond the scope of a SAR.
• Learn about responding to “keep open” requests from law enforcement agencies.

BSA Risk Assessment: Regulatory Requirements & Examiner Expectations
On-demand (20 mins.)

Speaker: Colleen Kelly

A comprehensive risk assessment of a credit union’s products, services, members and geographic locations is the foundation of an effective BSA/AML/CFT compliance program. While attempts to launder money or conduct other illegal activities through a credit union can emanate from many different sources, certain products, services, members and geographic locations may be more vulnerable.  This session reviews the regulatory requirements and examiner expectations of a credit union’s BSA Risk Assessment. 

Learning Objectives:

• Through a survey exercise, learn to determine how to assess low, moderate and high risk of members and accounts.
• Review the latest information regarding the 2020 “de-risking” statutory requirement that prohibits credit unions from “terminating, failing to initiate or restrict a high-risk business relationship.”
• Identify NCUA’s Risk Assessment examination expectations.

Performing Enhanced Due Diligence for Higher-Risk Accounts
On-demand (40 mins.)

Speaker: Colleen Kelly

FinCEN states that performing due diligence for all credit union accounts is critical to an effective BSA/AML/CFT compliance program.  This information is used to develop a baseline against which member activity can be assessed for possible suspicious activity reporting.  This session looks beyond the basic member due diligence regulatory requirements reviewed in the BSA 101 session by considering how to apply the regulations to higher-risk accounts, products and members. 

Learning Objectives:

• Explore how to effectively perform due diligence for several higher-risk accounts, such as business accounts, MSBs, cannabis related businesses, nonresident alien accounts.
• Review what credit unions can do to mitigate their risk of these potentially higher risk accounts.
• Identify NCUA’s Member Due Diligence examination expectations and consider what credit unions can do to prepare for their next exam. 

OFAC Compliance: Beyond the Basics
On-demand (28 mins.)

Speaker: Valerie Moss

The Office of Foreign Assets Control (OFAC) requires credit unions to “block” (i.e., freeze) property and reject certain transactions involving U.S.-sanctioned countries, entities, and/or individuals appearing on OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN List”) and Consolidated Sanctions List. It is critical that a credit union’s OFAC compliance program possess the appropriate internal controls for screening OFAC targets and reporting prohibited transactions in order to comply with these requirements.

Learning objectives:

• Find out when to block property and when to reject prohibited transactions.
• Take a closer look at how to handle various transactions (e.g., checks. ACH, wires) and transaction parties (e.g., check payees, ACH/wire recipients, etc.)
• Learn how discern “false positives” and when to contact OFAC for assistance.
• Explore common OFAC violations and some tips on how to best prevent them.

314 (a) & (b) Information Sharing 
On-demand (15 mins.)

Speaker: Valerie Moss

Section 314 (a) of the USA Patriot Act allows law enforcement agencies to solicit information from financial institutions via a FinCEN information request.  Section 314(b) encourages financial institutions to voluntarily share information in order to identify and report activities that may involve money laundering or terrorist activity. In this session, we’ll build from your level 101 training on this topic.

Learning objectives:

• Solidify your understanding of 314(a) search requirements
• Learn 314(b) voluntary information sharing do’s and don’ts
• Review confidentiality and documentation requirements

Reporting Cyber-Events and Cyber-Enabled Crime
On-demand (23 mins.)

Speaker: Valerie Moss

FinCEN has released a number of advisories on when and how to file SARs related to cyber-events and cyber-related crime.  Find out the agency’s expectations and recommendations related to this important aspect of BSA compliance.

Learning objectives:

• Review the red flag indicators of various types of cyber-attacks (e. g., phishing, malware, DDoS attacks, etc.)
• Learn when and how to report cyber-enabled crime and cyber-events on SARs
• Learn what cyber-related information is helpful to law enforcement (e. g., Internet Protocol (IP) addresses with timestamps, virtual-wallet information, device identifiers)

Human Trafficking
On-demand (45 mins.)

Speaker: Colleen Kelly

Human trafficking is a modern-day form of slavery.  Victims of human trafficking are subjected to force, fraud, or coercion, for the purpose of sexual exploitation or forced labor.  According to Homeland Security, after drug dealing, trafficking of humans is tied with arms dealing as the second largest criminal industry in the world, and the fastest growing.   In this session we will explore how credit unions can play a critical role in combatting this heinous crime.  

Learning objectives:

• Debunk 8 common myths regarding human trafficking.
• Review case studies to illustrate the many faces of human trafficking.
• Identify risk factors & high-risk areas.
• Learn to recognize trafficking red flags, including FinCEN’s 2020 updates.

Senior Financial Exploitation: How to Spot It & How to Stop It
On-demand (65 mins.)

Speaker: Colleen Kelly

The COVID-19 pandemic has exacerbated a growing problem for seniors in the United States: Senior Financial Exploitation. With older Americans more isolated from their loved ones than ever, they are becoming more susceptible to losing their savings to fraudsters.  Even before the coronavirus, the financial cost of elder financial fraud was staggering.  Credit union professionals are uniquely positioned to play a vital role in preventing and responding to this type of fraud because they often have the opportunity to see fraudsters face to face and can detect unusual activity in member accounts. This session will meet the training requirement needed for the credit union to ensure immunity from liability when sharing member information with third parties to report suspected senior financial exploitation.

Learning objectives:

• Review the reporting and training requirements of the Senior Safe Act in the 2018 Regulatory Relief Bill.
• Discuss the CFPBs recommendations to prevent and respond to senior financial exploitation.
• Identify red flags that could indicate unusual behavior or suspicious financial activity of older members.

CUNA/NASCUS Office Hour for BSACS Certification

Tuesday, October 10, 2023
10:30 - 11:30 a.m. CT

Speakers

- Melisa Kallestad
- Colleen Kelly
- Valerie Moss
- Isaida Woo

This session is optional and is designed for attendees who are working toward earning the BSACS designation. After completing the BSACS certification exam and viewing the on-demand Level 201 sessions, what questions have come to mind?  We’ll use this time to answer BSA/AML/CFT questions related to the on-demand Level 201 training as well as questions about the eSchool and certification process.  

Learning objectives:

• Get your questions answered regarding Level 201 content
• Gain insights from CUNA and NASCUS staff regarding BSA/AML resources

Wednesday, November 29

10:30 – 10:40 a.m. CT - Welcome

Speakers:
- Melisa Kallestad
- Craig Money
- Isaida Woo

10:40 – 11:10 a.m. CT - General Session: Your BSA Filings are More Valuable Than You Know

Speaker: Tyler Hatcher, IRS-CI

11:00 – 11:25 a.m. CT - Break

11:25 a.m. – 12:15 p.m. CT -  General Session: Combating Financial Crimes from a Law Enforcement Perspective Panel

Panel:
- Tyler Hatcher, IRS-CI
- Sean Van Schaften, FBI
- TBA

Moderator: TBA

During this executive and senior-level Law-Enforcement-only panel, you will hear directly from the agencies that review and build cases from your SARs. These senior-level law enforcement leaders will address agency priorities, emerging money laundering/fraud crimes, typologies, and red flags identified in their financial investigations. Each agency will discuss the importance of SARs, SAR narrative best practices from a Law Enforcement perspective, and how Credit Unions can better partner with Law Enforcement for more effective public/private partnerships and financial crime investigations.

12:15 –12:45 p.m. CT - Break

12:45 – 1:45 p.m. CT - General Session: ICYMI Latest BSA Developments

Speakers:
- Colleen Kelly
- Valerie Moss

As criminal enterprises continually re-invent scams and fraud to avoid detection, law enforcement agencies must expand their Anti-Money Laundering/ Countering the Financing of Terrorism (AML/CFT) investigative and enforcement priorities. Congress recognized this by passing the most significant Anti-Money Laundering and Beneficial Ownership laws in a decade. Because credit unions play a critical role in supporting law enforcement’s efforts, this session will help credit unions prepare for the many new requirements mandated by these new laws, as well as keep up with the latest criminal trends. In this session, we will review recent changes to all AML/CFT related laws, regulations, guidance, and advisories.   

 Learning objectives: 

• Explore the new AML/CFT requirements in the Anti-Money Laundering Act of 2020
• Gain an understanding of the sequence of beneficial ownership rules and their requirements
• Review the AML/CFT Guidance and Advisories issued in 2020 – 2023
• Learn about the most recent changes to the FFIEC ‘s BSA/AML Examiners’ Manual  

1:45 – 2:00 p.m. CT - Break

2:00 – 3:00 p.m. CT - Breakout sessions (Level 201 & 301):

Level 201: Developing an Effective BSA/AML Training Program

Speaker: Tim Behunin

Bank Secrecy Act (BSA) training is required annually for virtually all staff at your Credit Union.  As the individual responsible for delivering this important information, you may find that staff is less than enthusiastic about taking this training and that developing content can be difficult and problematic. The good news is, it doesn’t have to be.  

Tim Behunin, a compliance and training professional with over 31 years industry experience, will share best practices in BSA training.  His time-tested techniques will assist you in developing a powerful and engaging BSA training program that puts you on the path of least resistance for meeting training requirements.  

              Learning objectives:

• Learn how to build a framework for BSA compliance training
• Identify BSA training requirements
• Learn how to develop quality training materials

Level 301: Artful Dodgers: How Criminals Use Art and Antiquities to Facilitate Financial Crimes

Speaker: Liz Fraccaro

This informative talk, with Antiquities Coalition's Legal Consultant and Financial Crimes Task Force Project Manager Liz Fraccaro, will examine how the lack of AML regulations on the art and antiquities markets in the United States created an attractive opportunity to financial criminals and kleptocrats for fraud, terrorist financing, money laundering tax and sanctions evasion.  The session will describe some “lessons learned” from the actions of corrupt actors to manipulate auction and business processes within the global art sector as a means to store and move value through art and antiquities, and how these lessons have been used in framing new laws and regulation, and what remains to be done and opportunities for market stakeholders, governments, and policy makers to better protect the legal art and antiquities markets and US financial system.

           Learning objectives:

• Learn how corrupt actors manipulate the legal art market for illicit means
• Understand comparative legal and regulatory frameworks from other market nations
• Hear what the US is doing, and has yet to do, to address the problem

3:00 – 3:15 p.m. CT - Day 1 Wrap Up

Thursday, November 30

10:30 – 10:35 a.m. CT - Welcome 

Speaker: Craig Money

10:35 – 11:35 a.m. CT - General Session: Fraud and BSA

Speaker: Chelsea Treboniak

11:35 – 11:50 a.m. CT - Break

11:50 am – 12:50 p.m. CT  - General Session: Regulatory Panel

Panel:
- Andrew Bludorn
- Delton Carter
- Winnefred Jackson

12:50 –1:20 p.m. CT - Break

1:20 – 2:20 p.m. CT - Breakout sessions (Level 201 & 301): 

Level 201: Ten Habits of a Highly Effective BSA/AML Professional

Speaker: Sarah Beth Felix

As financial crimes grow increasingly complex, regulatory partners are showing increased scrutiny, and the span of expertise a BSA/AML professional requires widens, how can you, as a BSA/AML professional, remain both motivated and successful? During this session, you will have the opportunity to hear from two experienced BSA/AML professionals who will share 10 habits to help make you become a skilled, effective, and successful BSA/AML professional. They will share lessons learned, challenges faced, and ways to ensure success. From broader skills of earning a seat at the table, building a brand and expertise, and trusting your voice, to more technical skills of executing a compliant BSA/AML program, keeping up and implementing regulatory changes, and building a strong relationship with the Board, examiners, and your team. You will walk away with 10 powerful habits that will impact your program and you as a professional.

Level 301: AI – What Is It and How Can It Help Me?

Speaker: Sue Landauer

AI, AI, AI, that's the buzz all around these days. Do we really understand what it is? Is your credit union using it now? And are there additional ways we could be using it to make all of our jobs easier? Let's explore this hot topic together and brainstorm about how we can use it for our BSA monitoring.

Learning objectives:

• Understand what AI is.
• Understand common uses credit unions are currently using AI.
• Look to the future for other uses of AI, including BSA monitoring and possible financial crimes.

2:20 – 2:30 p.m. CT - Break

2:30 – 3:00 p.m. CT - General Session: Fireside Chat

Speakers:
- Sarah Beth Felix
- Craig Money

Sit back, relax, and listen to this conversational discussion between Craig Money, AVP – Operational Risk and BSA Officer, Community Financial Credit Union, and a special guest.

3:00 – 3:15 p.m. CT- Wrap up and Next Steps