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Cybercrime, the Invisible Gunslinger Threatening Your Financial Institution
Unmasking the 21st Century Bank Robber
By Lori Moore, Director of Compliance
In the old west, banks knew their enemy. Larger than life criminals such as Jesse James and Butch Cassidy were well known for brazen robberies that left bankers quaking in their boots. The Great Depression inspired another generation of highly recognizable bank robbers, as the likes of John Dillinger, Ma Barker, and Bonnie and Clyde terrorized banks across the Midwest in the 1930s. While armed bank robbery still occurs occasionally, today’s financial institutions are prepared to deal with gun toting criminals with security guards, surveillance cameras and teller panic buttons. These proactive solutions combined with stiff federal laws have deterred the traditional gunslinger almost to extinction. Rather than breathing a sigh of relief though, financial institutions now need to turn their attention to an enemy not nearly as well known but potentially far more dangerous. The cyber criminal is not only invisible, he or she has the ability to render your financial institution and/or your customers defenseless with nothing more than a keystroke.


Get a Gold Star on Your ACH Audit!
Have you revised your ACH Audit plan for 2010? If not, you won’t want to miss this session! Attendees will learn about the Rules Audit Enhancement rule amendment which went into effect December 18, 2009 and how these changes impact the 2010 ACH Audit. Just reading the audit requirements in the ACH Rules can be mind-boggling! This session summarizes the best practices to help Financial Institutions achieve an ACH audit that is fully compliant. We will also discuss areas that should be reviewed that are not included in "Appendix Eight", but can result in monetary loss and exposure.
Speaker: Pam Rodriguez, AAP, CIA, CISA
EastPay
5/25/2010 3:00PM ET to 4:00PM ET


Question: We do not originate IAT transactions, however we do receive them. What is our SAR filing responsibility for IAT Transactions which are not payroll or pension payments?
Answer:
The 2010 BSA/AML Examination Manual recently issued by the FFIEC provides two examples of situations involving an IAT where one was originated for payroll and the other for a pension payment. It does not state that all IATs will typically only be originated for these two purposes. At this time, I’m not aware of any guidance that states or implies that an IAT transmitted for any other purpose should be deemed suspicious. Therefore, a Suspicious Activity Report (SAR) should not be filed solely on the basis that an IAT – whether it is originated or received by your institution - was transmitted for a purpose other than payroll or pension payments. All IATs must be scanned for OFAC compliance and if your institution feels that the transaction is unusual or suspicious for any reason, an SAR should be filed as required.
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.

Tippett's Top 10 Security Predictions
By Linda McGlasson, BankInfoSecurity.com
Now, I've always been a "glass half-full" kind of optimist, and a recent presentation by a well known security expert almost makes me feel all warm and fuzzy inside. Peter Tippett, head of Verizon's information security team, told attendees at a London information security trade show that security protection in the next 10 years will become more effective and widespread.
"While we can never fully forecast the future, we certainly have a good glimpse into what security will be like 10 years from now -- based on all the data we have amassed over the last several years for our Data Breach Investigations Reports," Tippett says. "For starters, we know successful security breaches are leveling off, and that means we are headed in the right direction as organizations band together to fight cybercrime. By 2020, we expect life to be notably better for cyber users."
Tippet's top 10 predictions...

Agencies Release Revised BSA/AML Examination Manual
FFIEC.gov
The Federal Financial Institutions Examination Council (FFIEC) released the revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. The revised manual reflects the ongoing commitment of the federal and state banking agencies to provide current and consistent guidance on risk-based policies, procedures, and processes for banking organizations to comply with the Bank Secrecy Act and safeguard operations from money laundering and terrorist financing. The 2010 version further clarifies supervisory expectations since the August 24, 2007 update. The revisions again draw upon comment from the banking industry and examination staff.
The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency, Office of Thrift Supervision, and State Liaison Committee revised the manual in collaboration with the Financial Crimes Enforcement Network, the administrator of the Bank Secrecy Act, and the Office of Foreign Assets Control.
Revisions were made throughout the manual. The sections of the manual with more significant updates are again noted in the table of contents.
The manual is located on the FFIEC BSA/AML InfoBase. Banks and credit unions should direct questions about the manual to their primary federal regulator.

Most Customers Don't Want to be "Friends" With Banks, Yet
Bank Technology News
If you don't think it makes much sense for banks to be putting a lot of energy into FaceBook and Twitter applications--despite what marketing teams think--new survey results from Javelin Strategy & Research provide some backup for your position.
Though going where your customers are is the mantra--and 52 percent of online adults and 82 percent of core millennial use social networks--most consumers can't fathom a great reason to interact with their banks there. "There's a 7:1 ratio of consumers who say, 'I don't see a connection between social networking and banking,'" says Javelin analyst Mark Schwannhauser.
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