BSA AML Slide Jim Phillips


On April 13, Jim Phillips gave a virtual presentation to the Birmingham Chapter of InfraGard. The program was broadcast from a studio at the offices of Kossouf and Company, CPAs and available to InfraGard chapters around the country. InfraGard is a partnership between the Federal Bureau of Investigation (FBI) and members of the private sector for the protection of U.S. Critical Infrastructure, including the financial sector. Jim is a board member and Financial Sector chair of the Birmingham chapter. The presentation was entitled BSA/AML After the Anti-Money Laundering Act of 2020: Where Do we Go From Here? The AMLA is the most comprehensive set of reforms to the BSA/AML laws in the United States since the USA PATRIOT Act was passed in 2001. The presentation included a brief history of legislation, as well as the priorities , standards, and challenges facing BSA compliance professionals. Jim emphasized the potential of significant litigation as a result of the AMLA whistle blower program which in turn will likely lead to a wave of new BSA investigations and enforcement actions by FinCEN. Jim also outlined some of the AMLA provisions which will require bank customers to self-disclose beneficial ownership information to a national registry maintained by FinCEN and allow law enforcement and financial institutions to access that data with certain conditions. He also discussed clawbacks applicable to partners, directors, officers, or employees of financial institutions convicted of violating the BSA which would require them to repay any bonuses during the calendar year during which or after the violation occurred.  Please contact EAP or Jim Phillips directly for any assistance with your BSA/AML programs.


Leave a Reply

Your email address will not be published. Required fields are marked *