Living with IAT    
Whose Responsibility Is It, Anyway?
By Lori Moore, Director of Compliance

"The buck stops here." President Harry Truman’s famous quote and desk sign reminded everyone, including himself, that he was the end of the line; he had the ultimate responsibility for decisions impacting the United States.  

Where does the buck stop in complying with NACHA’s fairly recent rules on International ACH transactions (IATs)? Is it with the originating party that initiates the ACH? Or is it further down the line with either of the depository financial institutions (DFIs), the ACH Operators, Gateway Operators (GOs) or the receiver? The truth is each of those parties has responsibility, and no one has the luxury of passing the buck.  

Although the transition to living with NACHA’s IAT rules has been reasonably smooth, this is the one aspect that has caused considerable confusion, and therefore risky non-compliance, especially among corporate originators and originating depository financial institutions (ODFIs). It’s time to set the record straight.





Safeguard Your Systems With Host-Based
Intrusion Prevention

Although most companies use security devices such as firewalls and network IDS/IPS devices to protect their critical systems, in this day and age, many attacks by cyber criminals can literally bypass and subvert these systems. This webinar will demonstrate how a Host-Based Intrusion Prevention System (HIPS) can help you protect your mission critical systems from tampering, without breaking your budget. This session will also cover other topics which will help you safeguard your institution, including:

• Intrusion Detection, Prevention and the role of "Host-Based"
• Common methods hackers use to get YOU to compromise your own systems 
• Looking beyond detection to prevent malicious attacks
• Monitoring your mission critical systems 24x7

Speaker: 
Sebastian Fazzino, SVP 
Security & Compliance
Perimeter E-Security

7/27/2010 3:00PM ET to 4:00PM ET





Question: Regarding BSA/AML, what types of individuals or entities are considered high-risk?

Answer:  
An overview of the various types of customers and entities that are considered to be high-risk is included within the FFIEC BSA/AML Exam Manual. However, you should remember that the types of individuals and entities included in the manual may not be all inclusive. Regardless of the category or type of customer, determining the risk level is largely dependent upon factors specific to the customer. For example, all customers who are Politically Exposed Persons or PEPs are not necessarily all high-risk. Factors such as the geographic location or region to which the customer is related are significant considerations when determining risk.

Got a question on a tricky regulation? We want to hear from you! Submit your question and an expert will answer it in a future issue.



Are Mobile, Remote Deposit Capture Concerns Overblown?
By Tracy Kitten, bankinfosecurity.com

The security of mobile transactions - especially on the iPhone - has been questioned for years. Some of my concerns have been assuaged, based on conversations I've had with security experts. Gartner analyst Avivah Litan tells me that most security issues surrounding the iPhone have been addressed. The iPhone today, she says, is just as secure as any other mobile device.  But I still have some reservations about mobile RDC...is your institution ready to make the move?

Designation of Exempt Person & Currency Transaction Reporting
Assessing the Impact of Amendments to the CTR Exemption Rules
FinCEN.gov

In December of 2008, FinCEN published a rule intended to simplify and clarify the process by which depository institutions can exempt the transactions of certain persons from the requirement of reporting transactions in excess of $10,000. These rule amendments affected the requirements for two FinCEN filings, the CTR and the DOEP (Designation of Exempt Person) with goals of:

• Eliminating the need to file DOEPs for certain customers; and,
• Enhancing the value of the remaining CTR filings for investigative purposes by removing filings that FinCEN determined to have little or no value

• It appears likely that fewer CTR filings are being made on transactions of limited value to law enforcement
• The higher value CTRs that remain are becoming easier to identify

Your Talents, Your Career and Change
By Steve Roesler, AllThingsWorkplace.com

It's a win for everyone when you find the kind of organization in which your talents can flourish. But we live in a working-world filled with changes:

1. A CEO may decide it's more profitable to become a manufacturing-focused company than a sales & marketing-driven organization.

2. Mergers and acquisitions create new cultures. New cultures lead to new values and priorities.

3. Customers change their technology, causing your company to change it's tech service response.

4. Downsizing. Fewer people, more responsibilities for those remaining.

I've watched each of the above grow into a crisis of confidence for employees and employers...read more.