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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

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.


  • 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

  • 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 38 years of experience in financial institution supervision and consulting. Thomas has spent 30 years as a National Bank Examiner (NBE) for the Controller of the Currency, where he was a safety and soundness examiner and a compliance examiner. The last 15 years as an NBE and for the past 8 years as a consultant, he has specialized as an AML/CFT examiner/consultant. In these roles, he has analyzed financial institutions’ AML/CFT programs to ensure that they complied with applicable AML/CFT laws, rules, and regulations. He reviewed the suspicious transactions identification, monitoring, and reporting processes, he traced proceeds and transactions through several layers of activity, and he provided AML/CFT training for many different financial institutions. 

Thomas currently works as a consultant for the Office of Technical Assistance (OTA), a branch of the US Treasury that assists developing countries with banking issues. He 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, Vietnam, 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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