BSA/AML Contextual Awareness of High Risk Customers

Thomas E Nollner has more than 35 years of experience in financial institution supervision and consulting. Mr. Nollner spent 30 years as a National Bank Examiner for the Comptroller of the Currency where he was a safety and soundness examiner and a compliance examiner. As a safety and soundness examiner he examined national banks for capital adequacy, asset quality, management issues, earnings concerns, and liquidity funding. As a compliance examiner, he examined national banks for compliance with consumer laws and regulations such as the Truth-in-Lending Act, the Real Estate Settlement Procedures Act, the Flood Disaster Protection Act, the Community Reinvestment Act, and AML/CFT laws and regulations. His specialty was as an AML/CFT examiner, where he analyzed a bank’s AML/CFT program to ensure that it complied with applicable banking laws, rules, and regulations; he reviewed the bank’s suspicious transactions identification, monitoring, and reporting process; he traced proceeds and transactions through several layers of activity; and, he reviewed a bank’s processes and procedures to determine root causes of AML/CFT program weaknesses. Mr. Nollner currently works as a consultant for the Office of Technical Assistance (OTA), a branch of the U.S. Treasury that assists developing countries with banking issues. Mr. Nollner is assigned to the Economic Crimes Team that focused on training, assisting, and mentoring the staffs of the financial regulatory departments and financial intelligence units of various countries regarding AML/CFT compliance. In this capacity, he worked in countries such as Afghanistan, Iraq, Turkmenistan, Viet Nam, Honduras, Guatemala, Guyana, Suriname, and Argentina developing AML/CFT examination procedures, providing AML/CFT training and mentoring, and updating local AML/CFT laws and regulations.