Have you heard? We've recently enhanced our website. For more in-depth, easy-to-find regulatory compliance information & solutions for your industry, www.ATTUSTech.com.
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Congratulations to last quarter's winner, Gary Barth, Texas Community Bank, in The Woodlands, TX. Gary won an Amazon Kindle just for sharing his opinion and you can too! Just complete our reader survey & you'll be entered in our Kindle drawing. Check back monthly to see if you're the next winner.
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 The Current Hot Spots in BSA/AML Compliance
How to Keep Your Financial Institution from Getting Burned
By Lori Moore, CRCM, Director of Compliance
In last month’s discussion on Wire Fraud in The Compliance Advisor, we touched on two recent enforcement actions (EAs) issued by the OCC in conjunction with the Financial Crimes Enforcement Network (FinCEN) that resulted from inadequate Bank Secrecy Act/Anti Money Laundering (BSA/AML) compliance programs. Given the size of the fines imposed ($7 million and $8 million), now is a prudent time to revisit your BSA/AML compliance program to ensure your financial institution doesn’t meet a similar costly fate. Take some time to see just how well your program stacks up in the BSA/AML areas that appear to be garnering the most scrutiny and criticism from regulators: suspicious activity reporting, internal controls and independent testing.
OFAC 101: Does Your Company Play by the Rules?
Complying with OFAC is more complex than ever before. Do you have a comprehensive understanding of the term "OFAC Compliance" and how it impacts your industry? Attend this webinar and learn more about the history of OFAC since September 11, the responsibilities you have as a company to comply with OFAC regulations, and how you can avoid expensive penalties and fines as a result of OFAC violations.
Speaker:
Lori Moore, CRCM
Director of Compliance
ATTUS Technologies
6/29/2011 3:00PM to 4:00PM ET
 Question: Regarding OFAC SDN List screening, is the statute specific on the matching? Ex. is it correct that all data must match the individual exactly?
Answer:
There really isn’t a legal “statute” that sets forth the process for qualifying and disqualifying a potential match. The decision tree provided on the OFAC website describes the steps you should take to determine if you have a positive match or not prior to contacting OFAC for assistance. You should compare as much of the identifying information obtained from the subject person to that included in the SDN list records. If a substantial amount of the information matches, such as name, address, DOB, nationality, and/or government issued ID number, you most likely have a positive match. However, the type of information that is similar, rather than the amount, may also indicate a positive match. This might include the name, ID number, and nationality or country of residence. Once this comparison is complete, you should contact OFAC for further assistance and/or instructions. Conduct as much due diligence as possible before calling.
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.
Citi Breach: A Warning to Banks
No Institution is Immune to Today's Sophisticated Attacks
Tracy Kitten, BankInfoSecurity.com
Industry experts agree it's too early to say how hackers managed to infiltrate Citi's online banking platform. But they all say the breach, which could have exposed personally identifiable information about 200,000 Citi customers, should serve as a wake-up - not just for Citi, but all banking institutions.
Even though Citi - and the major banks in general - clearly takes security seriously and invests significant resources to protect its data assets, something like this can still happen.
Latest Surprise from Dodd-Frank: The '200 Dollar Rule'
Final Reg CC rule change effective July 21
Carl Pry, bai.org
One of the most confusing things about the Dodd-Frank Act is figuring out the effective date of the deluge of new regulations coming from the Act.
On March 3rd of this year, the Federal Reserve issued a proposal amending Reg CC, which was published in the Federal Register on March 25. The amendments would entitle banks to expeditious returns of checks only if they agree to electronic receipt, permit paying banks to require checks be presented for same-day settlement electronically and shorten the exception hold period to four business days (from seven).
However, included in this lengthy proposal is a Dodd-Frank mandated increase in a Reg CC provision known as the “$100 rule” to $200. This provision states that banks must make $100 of the day’s deposits available by the next business day after the day of deposit, unless a proper exception hold is taken.
The frustrating part is that this $200 rule change is final as of July 21, even though this fact is not mentioned in the Fed’s press release at all. It’s not listed in the initial summary of the Fed’s proposal document nor does it appear in the “Dates” section either. It’s scattered throughout the document and isn’t first mentioned until page six. Are you ready for the change?
Be Generous at Work
How Generosity Can be a Key Driver of Success
Jodi Glickman, hbr.org
If you took a poll of critical skills most important to business success, you'd be hard pressed to come up with a list that didn't include vision, leadership, drive, ambition, or intellect. You'd be equally hard pressed to find one that included, much less led with, generosity. That generosity is important and valued isn't news — but a key driver of success? That's not often where it lands.
Generosity is more typically an afterthought, a by-product, a "nice-to-have" quality. If a manager or leader is generous, they're probably well liked. But it's more than that: Elegantly simple, yet extremely powerful, generosity can make your career.
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