1. Fiduciary & Investment Risk Management Association
National Risk Management Training Conference
April 2008
    
C. Rachel Raemore Romijn Senior Vice President Compliance Director Wachovia Corporation

2. Overview of Presentation
Overview of Strong AML Program: WARRCOM – What is it?
Customer Due Diligence in Detail
Assessments in Detail

3. Alphabet Soup….
SEC
FRB
BSA
OCC
FINRA
USA PATRIOT Act
IRS

4. 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
     

5. Written Policies and Procedures
     
Cascading Policies
FFIEC Analysis and 2006 Updates
312 Implementation

6. Awareness and Training
Everybody should get something
Web based Training Module
Specialized Focused Training
PEPs
Offshore Companies and Trust
312

7. Regulatory and Internal Reporting
Regulatory Reporting
such as SARs, CTRs, 314, 311
Centralized Escalation
Score Card and MIS

8. Customer and Product Due Diligence
Ongoing Monitoring of all Clients
Independent in-country visits for certain types of clients
High Risk Codes
312
New Product Committee

9. Specific Issues…… In a High Touch Space
High Touch Due Diligence Process and Relationship….
So you should know and understand client – get to
the warm body
Know and continue to know their reputation
Source of Wealth
Proactively vet PEP risk

10. Specific Issues…… In a High Touch Space
Mostly Managing Reputational Risk….Not Just AML
Coordinate Actions for or against the client…Red Flag Committee Structure

11. Oversight Management – “How do you know?” Compliance & Risk Management
Internal Audits
External Audits
Regulatory Exams

12. Monitoring and Assessments
People and Automated Systems
Assessment Program
Automated Tools
Escalation
Ongoing Due Diligence
of Customers and Products

13. What is an Assessment?
Risk Assessment of high risk types looking at products, customers, and geography
Self Assessments of policies and processes
Risk Matrix and on-going Surveillance
     

14. Four Main Elements to AML Assessment Program: WRAP
W: WARRCOM Quality Assessment
R: Risk Matrix or Score Card
A: Audit, Compliance and Regulatory Examination Results
P: Policy development based on Products and Services, Customer Types and Geographies

15. Policy Development Based on Products and Services, Customer Types and Geographies
     
Products and Services
Who are you? Customer Types
What do you want? Products and Services
Where are you from? Geographies

16. (W: WARRCOM Quality Assessment) Self Assessments
     
What does success look like?
How are GAPs resolved and tracked?
Are reports issued?

17. R: AML Risk Matrix The Facts
AML Risk Matrix or Score Card: Incorporate FFIEC Appendix J & M and Additional Questions for all AML Risk Assessment Units

18. A: Audit, Compliance and Regulatory, Examination Results
Add Internal Audit Results
Summarize Compliance Review Results
Add Regulatory Results

19. Resources: More than FFIEC Manual
Securities Industry and Financial Markets Association (SIFMA) Anti-Money Laundering and Financial Crimes Committee 2008 Guidance for Deterring Money Laundering and Terrorist Financing Activity, February 2008
FINRA a Small Firm Template, Anti-Money Laundering Program: Compliance and Supervisory Procedures
SEC Anti-Money Laundering Source Tool
FinCEN’s Guidance, Application of the Requiring Special Due Diligence Programs for Certain Foreign Accounts to the Securities and Futures Industries, May, 10, 2006