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In recent years the increased use of electronic means to obtain customer signatures, to conduct verifications of customer information, and to conduct overall customer due diligence has posed problems for financial institutions to fully comply with KYC, CDD/EDD requirements. This webinar will discuss methods of using electronic means for these activities and will discuss up-to-date guidance provided by FinCEN and financial regulators in the use of electronic platforms for these processes. As electronic technology increases in the financial sector, staff and employees of financial institutions must be aware of the methods of electronic information gathering, and the risks associated with this type of information gathering.


  • An overview of FinCEN and regulatory requirements and guidance related to electronic information gathering
  • Defining exactly what constitutes an E-Signature, and E-Verification, and E-CDD/EDD
  • Common mistake financial institutions make related to electronic information gathering
  • Internal controls needed to ensure that electronic information gathering complies with AML/CFT laws and regulations
  • Needed additions to KYC and CDD/EDD policies, procedures, and practices to improve current bank guidance
  • Regulatory expectations for compliance with electronic information gathering

  • FinCEN regulations and guidelines related to electronic information gathering
  • FFIEC and other regulatory requirements and guidance
  • Items to include in your electronic information gathering policies, procedures, and practices
  • Current industry standards and business norms related to electronic information gathering
  • Recent enforcement actions related to weak programs and practices
  • Proposed future issues related to electronic information gathering

Financial institutions need to be aware of the latest trends in emerging technology related to electronic information gathering. This presentation will allow attendees to obtain background information of how this new technology affects KYC and CDD/EDD information gathering and verification, it will explain to attendees how this new technology is constantly changing, and the presentation will provide attendees with the latest guidance and information from financial regulators and FinCEN.


  • Front line BSA/AML staff 
  • Account opening/customer service staff
  • BSA/AML officers
  • Compliance officers
  • BSA/AML audit staff
  • Suspicious activity information review staff, investigators, and SAR 
  • Decision-makers
  • Risk managers

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.

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