Hot Topics in AML

114 Pages·2017·15.56 MB·English

Hot Topics in AML (AML)
Tuesday, May 16
1:45 p.m. – 2:45 p.m.

Join FINRA staff and industry panelists as they discuss noteworthy topics around anti-money
laundering, and their approach to address and combat money laundering risks.

Moderator: Jason Foye
Examination Manager
FINRA Anti-Money Laundering Investigations Unit (AMLIU)

Panelists: Brent Cohen
U.S. Head of AML Compliance
RBC Capital Markets, LLC

Sterling Daines
Deputy Head of Financial Crime Compliance
Goldman, Sachs & Co.

John Fahey
Branch Chief, Office of Chief Counsel, Division of Trading and Markets
U.S Securities and Exchange Commission (SEC)

© 2017 Financial Industry Regulatory Authority, Inc. All rights reserved. 1
Hot Topics in AML (AML) Panelist Bios:

Moderator:

Jason Foye is Examination Manager in FINRA's Anti-Money Laundering Investigations Unit (AMLIU).
In this role he manages a team of eight examiners located throughout the country and has responsibility
for managing AMLIU investigations, consulting with other FINRA staff nationally on AML-related
examination, assists in the development of FINRA’s AML priorities and delivers AML training to FINRA
staff and associated persons of member firms. Mr. Foye has been with FINRA for 10 years and
previously worked as an examiner in the Florida District before assisting in the AMLIU’s creation five
years ago. He is a graduate of FINRA’s Excellence in Management program at Wharton and is a
Certified Anti-Money Laundering Specialist (CAMS), a Certified Fraud Examiner (CFE) and has been
an invited speaker at numerous industry sponsored conferences focused on AML trends and issues.

Panelists:

Brent P. Cohen is the U.S. Head of AML Compliance at RBC Capital Markets, LLC responsible for
oversight of AML, sanctions and the financial crime program for the institutional trading business,
investment banking, corporate banking and the Royal Bank of Canada-New York branch. Prior to RBC
Capital Markets LLC, Mr. Cohen served as the Director of AML Compliance within FINRA’s
Enforcement Department. His primary responsibilities included assisting with anti-money laundering
issues arising in investigations and examinations, as well as advising staff FINRA-wide on issues
involving the handling of suspicious activity reports (SARs). Before FINRA, Mr. Cohen was a vice
president in the AML-Suspicious Activities Group at Goldman Sachs & Co. In that role, he was
responsible for investigating potentially suspicious activity across the firm's various business lines,
including private wealth management, prime brokerage and clearing and execution. Mr. Cohen also
previously served as an assistant general counsel in the Money Laundering Prevention Group at UBS
Financial Services, Inc., where he investigated possible violations of the Bank Secrecy Act ("BSA") and
provided legal advice to business units concerning BSA requirements and the implementation of the
firm's policies and procedures. Mr. Cohen received his B.A. from the State University of New York at
Albany, from which he graduated summa cum laude, and his J.D., with honors, from the University of
North Carolina School of Law.

Sterling Daines is deputy head of Financial Crime Compliance. He also manages the global Anti-
Money Laundering/Suspicious Activities Group (AMLSAG), which is responsible for executing the firm’s
anti-money laundering program firm wide. Mr. Daines joined Goldman Sachs in 2007 and was named
managing director in 2010. Prior to joining the firm, Mr. Daines was a principal in the Forensic and
Dispute Services practice at Deloitte Financial Advisory Services LLP, specializing in issues and
investigations related to anti-money laundering, international sanctions, fraud, anti-bribery and
corruption, and forensic technology within the financial services industry. He was also the national
leader of Deloitte’s Forensic Data Analytics practice and a consultant to numerous private and public
institutions, including the United States Department of Justice and the Financial Crimes Enforcement
Network. Mr. Daines is currently the co-chairman of the Anti-Money Laundering and Financial Crimes
Committee of the Securities Industry and Financial Markets Association (SIFMA) in the United States.
Mr. Daines also co-chairs the Wolfsberg Group, an association of thirteen global banks which aims to
develop frameworks and guidance for the management of financial crime risks. Mr. Daines earned a BA
in History and Government from The College of William and Mary in 1990.

John Fahey is Branch Chief in the SEC’s Division of Trading and Markets, Office of Chief Counsel. His
work focuses primarily on anti-money laundering issues related to broker-dealers. As a member of the
Office of Sales Practices, he also works on a range of broker-dealer regulatory issues, including those
affecting senior investors and the distribution of insurance security products. He is a graduate of the
Georgetown University Law Center, Georgetown University, and Lafayette College.
© 2017 Financial Industry Regulatory Authority, Inc. All rights reserved. 2
FINRA Annual Conference
May 16-18, 2017 • Washington, DC
Hot Topics in AML (AML)
Panelists
Moderator
 Jason Foye, Examination Manager, FINRA Anti-Money Laundering
Investigations Unit (AMLIU)
Panelists
 Brent Cohen, U.S. Head of AML Compliance, RBC Capital Markets,
LLC
 Sterling Daines, Deputy Head of Financial Crime Compliance,
Goldman, Sachs & Co.
 John Fahey, Branch Chief, Office of Chief Counsel, Division of
Trading and Markets, U.S. Securities and Exchange Commission
(SEC)
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FINRA Annual Conference © 2017 FINRA. All rights reserved.
To Access Polling
Under the “Schedule” icon on the home screen,
Select the day,
Choose the Hot Topics in AML session,
Click on the polling icon:
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FINRA Annual Conference © 2017 FINRA. All rights reserved.
Polling Question 1
1. What is the type and size of your broker-dealer?
a. Small to medium sized introducing firm
b. Large introducing firm
c. Large self-clearing firm
d. Clearing firm for other broker dealers
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FINRA Annual Conference © 2017 FINRA. All rights reserved.
Polling Question 2
2. What is the primary AML surveillance model used at
your broker-dealer?
a. Manual review of client activity
b. Exception reports
c. Scenario driven alerts
d. Other
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FINRA Annual Conference © 2017 FINRA. All rights reserved.
Polling Question 3
3. How much of a priority is data integrity and
governance in your AML program
a. It’s the most critical component
b. It’s important but it is an IT/operations function not an AML
function
c. There are more important areas we need to focus on
d. This topic is entirely new to me
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FINRA Annual Conference © 2017 FINRA. All rights reserved.
Polling Question 4
4. How does your broker-dealer integrate cyber security
and AML
a. AML and cyber are part of the same group
b. AML delegates to cyber who escalates activity for SAR
investigations and decisions
c. AML and cyber are still in isolated but we are working to
integrate
d. AML and cyber and do not communicate
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FINRA Annual Conference © 2017 FINRA. All rights reserved.
Polling Question 5
5. How does your broker-dealer integrate trade surveillance
and AML
a. AML and trade surveillance are part of the same group
b. AML delegates to experts who escalates activity for SAR
investigations and decisions
c. Trade surveillance is largely compliance/sales practice oriented
but we are working to create AML surveillance in this space
d. AML and trade surveillance are separate and not communicate)
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FINRA Annual Conference © 2017 FINRA. All rights reserved.