Given How AML and OFAC Laws Are Trending, How Do Banks,MSBs and Other Financial Institutions Develop, Implement andMaintain an Effective AML and OFAC Compliant Prepaid CardProgram in Today’s Landscape?

October 6, 2014 1:50pm


Susan Lea Smith
Senior Counsel, AML Compliance
Western Union

Dawn Steele
Vice President, Global Anti-Money Laundering and Trade Sanctions Officer

Marilyn Barker CAMS
Sole Proprietor
The Law Office of Marilyn D Barker

Judith Alison Lee
Gibson Dunn & Crutcher LLP

  • Integrating red fl ags into your AML and OFAC programs
  • The latest on the trending of AML laws toward “Fraud Facilitation Theory” and how it affects Prepaid
  • Evaluating your existing AML program and identifying areas of gap or weaknesses: Accountability for defi ciencies in AML programs; Effective ways to identify and verify customer information
  • Developing and implementing effective AML procedures; Role of technology in AML programs
  • Drafting contracts and agreements to support and enhance AML and OFAC compliance
  • AML efforts when not part of a bank centric program
  • Creating an OFAC risk assessment and compliance program within the context of prepaid: Prohibition on dealing with certain parties
  • List of people, entities and organizations that US businesses and banks not allowed to deal with
  • Assessing penalties for failing to comply with OFAC: Examining recent penalties issued by states; reaching settlement