John Byrne

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AML/BSA/SARS What are the issues
John Byrne American Bankers
Association Rick Small Citigroup, Inc.
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Current Regulatory Environment for AML Issues

• January 10th ABA Letter on Examination Problems
• March 8th BSAAG Meeting on MSBs
• March 30th Statement of Policy
• SAR Numbers Skyrocket
• Treasury Reviewing Cross-border Wire Issue
• Congressional Hearings
• June 30th --- Interagency Exam Procedures

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(No Transcript)
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What Keeps Me Awake At Night???
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Potential that detectible money laundering is
occurring in the institution
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• Riggs
• AmSouth
• UBS
• ABN Amro
• Standard Chartered
• Banco de Chile

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Terrorist Financing
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TOTALS for 19 HIJACKERS
DEPOSITS303,481.63
DISBURSEMENTS
303,671.62
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• FINANCIAL PROFILE
• FROM HIJACKERS DOMESTIC ACCOUNTS

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• Accounts were opened with cash/cash equivalents
  3,000 to 5,000
• Identification used to open the accounts were
  U.S. visas issued in Saudi Arabia or U.A.E.
• Accounts were opened within 30 days after entry
  into U.S.
• All accounts were normal checking accounts with
  debit cards
• Hijackers tended to open their accounts in groups
  of 3 or 4 individuals
• Occupation on opening statements would usually be
  student

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• Some of accounts were joint accounts with other
  hijackers using same address and same telephone
  number
• Hijackers would make numerous attempts of cash
  withdrawals which often would exceed the limit of
  the debit card
• High percentage of withdrawals were from debit
  cards vs. low percentage of checks written with
  no normal living expenses for rent, utilities,
  auto payments, insurance, etc

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Embassy/Consulate accounts
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Public Figures/PEPs(Politically Exposed
Persons)PinochetArafat
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Correspondent BankingLatviaRussiaUkraine
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Suspicious Activity Report filings
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• Numbers
• Probable Cause
• Second guessing
• Grand Jury Subpoenas
• Defensive filings
• Should we file on everything?

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Regulators/Examiners
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What do we do?
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Manage Our AML Risk

• Policy development/Consistency of Policy
• Technology solutions
• Training
• Governance and oversight
• Internal control compliance monitoring
• Contact and interaction with governments
• Involvement in private sector initiatives