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A risk-based, time-saving approach to annual loan review

Abrigo

Instead of performing a covenant test as part of an annual review, keep this process separate. Underwriting financial transactions involves a level of detail that does not belong in your annual review process. Evaluation of the history of the transaction(s) since the last review. Review of outstanding documentation exceptions.

CECL 78
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OFAC Sanctions: Lessons from Deutsche Bank

Abrigo

Takeaway 2 Institutions need to conduct proper due diligence and ensure they are not completing transactions with entities on a sanctions list. Framework Document. On May 2, 2019, OFAC issued their Framework document, which is a must-read for anyone with sanctions responsibilities. CECL Models. Portfolio Risk & CECL.

CECL 78
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How to Conduct an Exam-Proof BSA/AML Risk Assessment

Abrigo

Takeaway 1 Documentation is one of the most critical aspects of performing a risk assessment. Document the BSA/AML risk assessment. Documentation is one of the more critical aspects of performing a risk assessment. Without supporting documents, the analysis of the institution's risk cannot be adequately supported.

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Using BSA Hot Topics to Strengthen Your BSA Program in 2020

Abrigo

This should all be documented in procedures and adhered to. Larger institutions should have a formal QC process and staff accordingly, and smaller institutions should have a QC program including, at a minimum, a random sample check of the riskier functions of the division. Other common BSA findings.

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A thoughtful approach to generative AI

Abrigo

This marked the advent of the platform economies with excellent digital experiences through fintech providers. After digital access and transactions came major boosts to automation for financial services. But the real lifestyle upgrade came when you had fintechs like Xoom and PayPal that made payments happen in near real-time.

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FinCEN announces $8 Million BSA Enforcement Action: The Resurrection of AML Penalties

Abrigo

T he CBOT enforcement action states that the bank failed to report hundreds of suspicious transactions to FinCEN even after the bank became aware that specific customer s were involved in criminal investigations. All triggering alerts should be thoroughly investigated and documented, period.

CECL 78
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FFIEC compliance: Ensuring access to suitable resources for effective BSA management

Abrigo

These penalties can accumulate daily and per transaction, resulting in significant financial and reputational damage. Documenting these requests and the board’s responses is also crucial, as it provides evidence during regulatory examinations that the compliance officer has taken the necessary steps to secure suitable resources.

CECL 78