How to Disposition Possible hits from Sanctions hits

This course will discuss procedures and processes your BSA department can employ when your institution is clearing and disposing alerts for potential hits identified by your screening process related to companies, individuals, and countries identified by government, international, internal, and other lists as sanctioned or of concern for money laundering, terrorist financing or other criminal activity.

• How sanctions lists are developed and why they are important?
• The numerous types of sanctions lists
• Who can be included on sanctions lists?
• What should a financial institution include in its sanctions list compliance program?
• How to determine if a potential hit is a true hit or just a false positive?
• How to clear a hit, either as a true hit or as a false positive?
• How to document the final decision?

There are many sanctions lists with numerous companies, individuals, and countries listed. As financial institutions conduct their reviews of these lists for the possibility that one of their customers may be identified on these lists, there is a high likelihood that some of these hits may be false positives. Since there are numerous companies and individuals with the same name, it is important that institutions know how to conduct further research and due diligence on these hits to make sure they are in fact true hits and not false positives. A financial institution must have a specific policy with procedures for employees to follow to ensure that all hits are researched and cleared and that false-positive are clearly identified.

This course will discuss the many areas involved with sanction lists such as: examples of who is included on these lists, a discussion of how the lists are compiled, methods you can use to analyze hits related to your customers and the lists, and ways you can ensure that a hit is properly disposed of either as a true hit or as a false positive.

• BSA/AML officers
• BSA/AML auditors
• BSA/AML staff
• Bank staff with onboarding responsibilities
• Bank staff with suspicious activity program responsibilities
• Staff related to the sanctions list process
• Investigators of sanctions list hits
• Researchers of sanctions list hits

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.