Cyber events and cyber-enabled crime have evolved into predicate offenses for money laundering. These must now be reported to the Financial Crimes Enforcement Network (FinCEN) via your financial institution’s suspicious activity report (SAR) process. This webinar will dissect FinCEN’s October 2016 Cyber-Events and Cyber-Enabled Crime Advisory and provide best practices for the creation and sustainment of a centralized function to address these new reporting expectations.
HIGHLIGHTS
Definition of the Financial Intelligence Unit (FIU) model for the collection, analysis, and dissemination of actionable transaction and cyber-related intelligence
Definition of “predicate offense” and why FinCEN’s guidance has national security implications specific to any cyber event or cyber-enabled crime
Deep dive discussion on new FinCEN expectations for cyber-enabled crime reporting
Reporting cyber-enabled crime and cyber events through SARs
Relevant cyber-related information in SARs (e.g., internet protocol (IP) addresses with timestamps, virtual-wallet information, and device identifiers)
Collaboration between BSA/AML units and in-house cyber security units to identify suspicious activity
Sharing information among financial institutions to guard against and report money laundering, terrorism financing, and cyber-enabled crime
Definitions of cyber event, cyber-enabled crime, and cyber-related information with corresponding SAR examples
Emerging need for an evolved “three lines of defense” model and how this new guidance may require creation of a fourth line: Cyber Intelligence Unit (CIU)
Overview of Joint OCC, FED, and FDIC Advanced Notice of Proposed Rulemaking (ANPR) on Enhanced Cyber Risk Management Standards specific to “interconnected” entities
TAKE-AWAY TOOLKIT
FinCEN’s October 2016 Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime with FAQs
Links to FFIEC’s BSA/AML Examination Manual InfoBase and FBI’s Internet Crime Complaint Center (IC3)
Joint OCC, FED, and FDIC ANPR on enhanced cyber risk management standards
Employee training log
Quiz you can administer to measure staff learning and a separate answer key
Attendance verification for CE credits provided upon request.
WHO SHOULD ATTEND? Electronic processing, information technology, and information security personnel, as well as auditors, compliance staff, risk staff, board members, audit committee members and BSA/AML/fraud analysts.
ABOUT THE PRESENTER – Brian Vitale, NCCO, CAMS-Audit, Compliance Advisory Service, earned his Political Science degree from North Central College in 1996 and an MBA from the University of Notre Dame in 2014. Brian was recruited by the National Security Division of the FBI where he specialized in counterterrorism and foreign counterintelligence. In addition, he is a decorated veteran who served in Guantanamo Bay, Cuba in the early 1990s.
Subsequent to the FBI, Brian spent many years in banking and finance where his skills led him to the field of Global Operational Risk Management. He has over twenty years of banking, finance, and investigative experience. In July 2011, Brian joined a community financial institution and currently serves as their chief risk and compliance officer. He speaks nationally on BSA, anti-money laundering, enterprise risk management, cybersecurity, and strategy.
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