There are many risks related to acquiring, maintaining, and supervising correspondent banking relationships which employees and management of financial institution’s need to be aware of and actively manage. With the enhanced scrutiny by regulators of a financial institution’s compliance program regarding correspondent banking relationships and the trend for financial institutions to rethink their decisions to maintain these relationships, it is important that employees and management of financial institutions are aware of and fully understand correspondent banking regulations and guidance.
This course will discuss the many issues related to KYC, CDD, risk rating, and the suspicious activity process as these relate to maintaining foreign correspondent relationships. In addition, the course will discuss the “de-risking” issue (a bank terminating a foreign correspondent relationship) and other current trends related to foreign correspondent banking.
Thomas E. Nollner has more than 38 years of experience in financial institution supervision and consulting. Mr. Nollner spent 30 years as a National Bank Examiner (NBE) for the Controller of the Currency where he was a safety and soundness examiner and a compliance examiner. The last 15 years as an NBE and for the past 8 years as a consultant, Mr. Nollner has specialized as an AML/CFT examiner/consultant. In these roles he has analyzed financial institutions’ AML/CFT programs to ensure that they complied with applicable AML/CFT laws, rules, and regulations; he reviewed the suspicious transactions identification, monitoring, and reporting processes;he traced proceeds and transactions through several layers of activity; and he provided AML/CFT training for many different financial institutions. Mr. Nollner currently works as a consultant for the Office of Technical Assistance (OTA), a branch of the U S Treasury that assists developing countries with banking issues. Mr. Nollner is assigned to the Economic Crimes Team that focused on training, assisting, and mentoring the staffs of the financial regulatory departments and financial intelligence units of various countries regarding AML/CFT compliance. In this capacity, he worked in countries such as Afghanistan, Iraq, Turkmenistan, Viet Nam, Honduras, Guatemala, Guyana, Suriname, and Argentina developing AML/CFT examination procedures, providing AML/CFT training and mentoring, and updating local AML/CFT laws and regulations.