Fiduciary & Investment Risk Management Association

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Presentation transcript:

Fiduciary & Investment Risk Management Association Financial Crimes in the Fiduciary and Wealth World March 2012      C. Rachel Romijn Senior Vice President BSA and FCPA Manager Wealth, Brokerage, and Retirement Wells Fargo

Overview of Presentation Unique and Not so Unique…… Not so….CIP, Monitoring So….Source of Wealth Analysis, Reputational Risk, PEP Vetting Not so and So…Geography Risk, Beneficial Ownership

Overview of a Strong AML/ATF/OFAC Program WARRCOM Written Policies and Procedures Awareness and Training Regulatory and Internal Reporting Record keeping Customer and Product Due Diligence Oversight Monitoring and Assessments      

Not so Unique… Customer Identification Program (CIP)       Customer Identification Program (CIP) Customer Due Diligence Currency Transaction Reporting Money Movement Monitoring SAR Reporting

Unique to Wealth and Trust… Source of Wealth Analysis…initial and on going Reputational Risk Large Relationships High Profile Clients Specialized Focused Training PEPs Offshore Companies and Trust Direct and Visible Involvement of RM

Retail Brokerage Twist… Securities Fraud Monitoring Coordination Among, Through and with Legal Entities

Unique and Not so Unique… Geography Risk….Independent in-country visits for certain types of clients Beneficial Ownership

New Developments Beneficial Ownership….. deeper dive for all Domestic PEPs???

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