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ACAMS 13th Annual AML & Financial Crime Conference

CH3 - Dealing with Foreign Clients and Cross-Border Requirements for Financial Institutions and Casinos

Sep 29, 2014 4:25pm ‐ Sep 29, 2014 5:40pm


The West Coast is a nexus of foreign financial activity into the US from Latin and South America and Asia. We face the ever present challenge of record keeping compliance and vetting our clients. However, in many cases the readily available information validating what is presented to us is somewhat lacking. This incompleteness and uncertainty has led many in the industry to engage in de-risking.

AML practitioners have indicated that verifying the source of income provided the most challenging area to include in their compliance plans. These challenges are in areas such as EB5 visa, validating foreign source of funds, and record keeping requirements especially in light of attempts to streamline international travel documentation requirements. Come join us for a discussion of the current roadblocks and strategies to put those clients back on your risk assessment.

Here in Vegas, the house always wins. Don't make KYC risk a game of chance; stack the deck in your favor.

Items we will cover:

  • EB5 requirements and difficulties
  • Border state issues in Mexico and Asia
  • Vetting foreign clients
  • Validating source of funds


  • James Vaughn, CFE, CAMS, Senior Internal Auditor, MGM Resorts International
  • Bob Frimet, CAMS, President, RMF Consulting Group
  • Lawrence Lin, CAMS, CFE, BSA/AML/OFAC/Compliance Officer, Bank of Communications San Francisco Branch
  • Mina Rizkalla, First Vice President, BSA Officer, East West Bank

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