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• Reviewing Patriot Act’s Section 312 to develop due diligence programs that are appropriate, specific, risk-based and designed to detect proceeds of foreign corruption
• Customizing assessments to reflect unique respondent bank risks such as domicile and business profile to ensure controls support correspondent bank risk appetite standards
• Delineating compliance and business side incentives to harmonize oversight in areas such as staff training, alert governance and conflict resolution involving respondent accounts
Moderator(s):
Timothy
C. McNeill,
CAMS,
Managing Director, Anti-Financial Crimes,
Deutsche Bank
Speaker(s):
Michael
Greenman,
Senior Vice President, Chief Counsel, AML and Economic Sanctions Law,
U.S. Bank