Optimizing Compliance through the Integration of AML and Fraud Prevention Broker-Dealers Perspective

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Optimizing Compliance through the Integration of AML and Fraud Prevention Broker-Dealers Perspective"

Transcription

1 Optimizing Compliance through the Integration of AML and Fraud Prevention Broker-Dealers Perspective Katherine M. Sikora Nelson Chair BNY Mellon Broker Dealer Anti-Money Laundering Oversight Committee

2 Agenda I. Fraud General Perspective II. III. IV. Suspicious Activity Report - Convergence of AML and Fraud Existing Tools at our Disposal Highlights Red Flags Rule Program Synergy with CIP/KYC Program, Credit Review and Fraud Prevention V. AML and Trade Surveillance Programs Detection of Securities Fraud VI. Escalations Process - Detection and Prevention By fighting fraud, you are fighting money laundering. And in turn, by identifying money laundering, you could be alerting law enforcement to activity intended to obscure the illicit source of the proceeds of fraudulent activity committed against innocent victims. JAMES H. FREIS, JR. DIRECTOR, FINANCIAL CRIMES ENFORCEMENT NETWORK ASSOCIATION OF CERTIFIED FRAUD EXAMINERS 20TH ANNUAL FRAUD CONFERENCE, LAS VEGAS, NV, JULY 13, 2009 ACAMS 8 th Annual International Money Laundering Conference

3 Section I. Fraud - General Perspective

4 Working Definition Fraud is generally defined in the law as an intentional false representation of a matter of fact whether by words or by conduct, by false or misleading allegations, or by concealment or omission of what should have been disclosed to state material facts that deceives and is intended to deceive another so that the individual will act upon it to her or his legal injury. The specific legal definition varies by legal jurisdiction. Fraud is a crime, and is also a civil law violation. In the U.S. legal system, state and federal statutes criminalize fraud, but not all cases rise to the level of criminality. Fraud must be proved by showing that the defendant's actions involved five separate elements: (1) a false statement of a material fact (2) knowledge on the part of the defendant that the statement is untrue (3) intent on the part of the defendant to deceive the alleged victim (4) justifiable reliance by the alleged victim on the statement (5) injury to the alleged victim as a result

5 Recent Statistics KPMG Survey Key Findings The majority of executives cite fraud and misconduct as posing significant risks to their industry today. Nearly two-thirds of executives (65 percent) reported that fraud and misconduct is a significant risk for their industry. If such wrongdoing were to be experienced, the greatest concern for over two-thirds of executives (71 percent) is the potential for a loss of public trust when market confidence is at a premium. Executives expect the threat of fraud to remain steady or rise in the coming year. About three out of four executives believed that fraud and misconduct risks, such as misappropriation of assets and fraudulent financial reporting, will either stay the same or increase over the next 12 months (85 percent and 74 percent, respectively). Inadequate internal controls or compliance programs heighten the risks of fraud and misconduct. Two thirds of executives (66 percent) reported that inadequate internal controls or compliance programs at their organizations enable fraud and misconduct to go unchecked. Executives acknowledge room for improvement across most elements of their antifraud efforts. Those areas where respondents cited the most amount of improvement needed include employee communication and training, technology-driven continuous auditing and monitoring techniques, and fraud and misconduct risk assessment (with 67 percent, 65 percent, and 60 percent of respondents, respectively, identifying at least moderate improvements needed). Source: KPMG Forensic Fraud Survey 2009 ACAMS 8 th Annual International Money Laundering Conference

6 Section II. Suspicious Activity Report Convergence of AML and Fraud

7 FinCEN Form Suspicious Activity Report by the Securities and Futures Industries 1. Bribery/gratuity 2. Check fraud 3. Computer intrusion 4. Credit/debit card fraud 5. Embezzlement/theft 6. Commodity futures/options fraud 7. Forgery 8. Identity theft 9. Insider trading 10. Mail fraud 11. Market manipulation 12. Money laundering/structuring 13. Prearranged or other noncompetitive trading 14. Securities fraud 15. Significant wire or other transactions without economic purpose 16. Suspicious documents or ID presented 17. Terrorist financing 18. Wash or other fictitious trading 19. Wire fraud 20. Other ACAMS 8 th Annual International Money Laundering Conference

8 The SAR Activity Review By the Numbers Issue 12 (June 2009) SARs characterizing the suspicious activity type as Significant Wire or Other Transactions without Economic Purpose increased 28% for 2008, as compared to the previous year which saw a similar increase from the prior year s-end. In 2008, SARs indicating Identity Theft as the suspicious activity type decreased 7%, compared to reports filed during 2007, which saw an increase of 83% from the preceding twelve months. While Identity Theft decreased, two suspicious activity types experienced notable increases in 2008: Credit/Debit Card Fraud (95%) and Mail Fraud (60%). Filings identifying the suspicious activity type as Securities Fraud increased 22% in 2008, compared to those filed in ACAMS 8 th Annual International Money Laundering Conference

9 Fraud by Whom, Against Whom AML compliance is not limited to the traditional view of what embodies money laundering. Customers Fraud: Against the Firm Against Third Parties and/or Customers underlying Customers, including: Investment Advisers, Hedge Funds, Pension Plan, Others Third Parties Fraud against the Firm and/or Firm s Customers Employees Fraud against the Firm and/or Firm s Customers Acts which may constitute criminal Fraud include: Mail, wire, phone fraud Internet (computer crime and internet fraud) Embezzlement, taking money which one has been entrusted with on behalf of another party, Forgery of documents or signatures Tax fraud (not filing revenues) or tax evasion (illegally avoiding taxes) Identity theft Credit card fraud Investment frauds, such as Ponzi schemes Securities frauds such as pump and dump

10 Section III. Existing Tools Already at our Disposal Suggested Considerations

11 Opportunities for Integration of Existing Compliance Infrastructure Section 314(b) Information Sharing with other Financial Institutions FinCEN Guidance on the Scope of Permissible Information Sharing Covered by Section 314(b) Safe Harbor of the USA PATRIOT Act (06/16/2009) Safe harbor expanded to allow for sharing of information to identify and report activities, such as suspected fraud - or other specified unlawful activities (SUAs) - if they suspect there is a nexus between the suspected fraud or other SUA and possible money laundering or terrorist financing activity Foreign Corrupt Practices Act ( FCPA ) FinCEN Guidance to Financial Institutions on Filing Suspicious Activity Reports regarding the Proceeds of Foreign Corruption - April 2008 Recent focus on FCPA compliance by FINRA newly developed exam module Company FCPA Policy Company Policy on Gifts, Entertainment and other Payments Politically Exposed Persons Review and Approval Process Foreign Domestic ACAMS 8 th Annual International Money Laundering Conference

12 Opportunities for Integration of Existing Compliance Infrastructure - continued Other Regulatory Requirements examples Surveillance Code of Conduct Business Continuity Plan and Information Security Customers Correspondence Customers Complains Review Process Subpoenas and Other Non-Routine Regulatory Inquiries Employees Personal Securities Trading Policy/Insider Trading Annual Compliance Meeting Credit Review and Approval, including Margin Account and Credit/Debit Cards associated with a brokerage account Red Flags Rule Program Trade Surveillance Programs Securities Fraud

13 Section IV. Red Flags Rule Program Synergy with CIP/KYC Program, Credit Review and Fraud Prevention

14 Red Flags Program Synergy with CIP/KYC Program, Credit Review and Fraud Prevention Federal Trade Commission s Red Flags Rule - promulgated in 2007, and implementing the Fair and Accurate Credit Transactions Act of 2003 Identity Theft Prevention Program ( Red Flags Rule Program ) applies to financial institutions and creditors with covered accounts Red Flags Rule Program Core Elements (effective November 1, 2009): Establish a written Program and identify relevant Red Flags for the covered accounts that the firm offers or maintains Monitor to detect relevant Red Flags that have been incorporated into the Program Respond appropriately to any Red Flags that are detected to prevent and mitigate identity theft Provide employees training Obtain approval of the written Program by the firm s board of directors or equivalent ACAMS 8 th Annual International Money Laundering Conference

15 Red Flags Program Synergy with CIP/KYC Program, Credit Review and Fraud Prevention - continued ACAMS 8 th Annual International Money Laundering Conference Update Program and its Red Flags periodically to reflect assessment of: 1) The types of covered accounts offered 2) The methods provided to open or access covered accounts 3) Previous experience with identity theft 4) Changes in identity theft risks to customers and the firm (impact of material changes to the business model) 5) Service provider arrangements Red Flags categories (out of the 26 examples): 1) Alerts, notifications or warnings from a credit reporting agency; 2) Suspicious documents; 3) Suspicious personal identifying information; 4) Suspicious account activity; and 5) Notices from customers, victims of identity theft, law enforcement authorities, or other businesses about possible identity theft in connection with covered accounts

16 Section V. AML and Trade Surveillance Programs Detection of Securities Fraud

17 Securities Typologies Potential Fraud Indicators Brokerage account being used as a depositary account: Clients receiving wires from multiple third parties Clients sending wires to multiple third parties Third party sending funds to multiple clients Multiple clients sending funds to a single third party Payments to multiple parties for same or similar odd amounts Check writing - checks paid to unfamiliar payees Multiple clients writing checks paid to the same payee Repetitious payments for unusual amounts Internet Based Accounts potential higher risk to engage in securities fraud, identity theft and/or account takeover/computer intrusion ACAMS 8 th Annual International Money Laundering Conference

18 Securities Typologies Potential Fraud Indicators - continued Journals entries of securities between unrelated accounts or for no apparent business purpose, being priced off the market Lack of trading - brokerage account used solely to custody of assets (indicia of unintended Prime Brokerage relationship) Trading patterns suggest Inside Information or Insider Trading Fraudulently inflated value of account assets for use as collateral for credit at another financial institution Prearranged or other non-competitive trading, including Wash or Cross Trades Historical Behavior Profile Deviation Trading Ahead of Market Events Asset Manager Cherry Picking Delayed Money Manager Allocations Death Puts as an Investment Strategy Deposit of Physical or Bearer Certificates Transactions involving Low Price Securities or Illiquid Securities (including portfolio valuation fraudulent schemes) ACAMS 8 th Annual International Money Laundering Conference

19 FINRA Regulatory Notice 09-05: Unregistered Resales of Restricted Securities It is a violation of federal securities laws for a firm to offer or sell a security without an effective registration statement or exemption from the 1933 Act A firm must have written procedures reasonably designed to avoid becoming participants in the potential unregistered distribution of securities Introducing Broker-Dealers may not rely on clearing firms or transfer agents to fulfill these obligations FINRA recently investigated and brought enforcement actions against several firms concerning unregistered distributions. Those firms failed to take steps to determine: How their customers had received the share certificates Whether their customers were control persons for the security The % of outstanding shares of the companies owned by their customers

20 FINRA Regulatory Notice 09-05: Unregistered Resales of Restricted Securities (continued) Red Flags Customer opens a new account and receives physical certificates representing a large block of thinly traded or low-priced securities Customer has a pattern of depositing physical certificates, immediately selling the shares, and then wiring out the sale proceeds Customer deposits share certificates that have been recently issued or represent a large percentage of the float of the security Share certificates reference a company or customer name that has been changed, or does not match the name on the account The lack of a restrictive legend seems inconsistent with the date the customer acquired the securities Suggested Remedy Firms should also try to physically inspect share certificates to identify Red Flags and/or deter risks from forgery or fraudulent certificates ACAMS 8 th Annual International Money Laundering Conference

21 Section VI. Integration Process Detection and Prevention

22 Integration Process Detection and Prevention Periodic AML Risk Assessment Quantity of Inherent Risk Quality of Risk Mitigation Residual Risk Rating and Direction of Risk Mapping of Efficiency Ensure that efforts are coordinated within the Firm Understanding client, counterparty, product and jurisdictional risk Be familiar with ever-changing regulatory issues, AML and Fraud typologies Track each specific requirement and its implementation across the Firm and across all related procedures Surveillance Maintain dynamic models and thresholds that can adjust to new lines of business, products and/or more complex scenarios Assure completeness of data running the automated surveillance models Combine review of the transactional data with the client profile details Engage in Reverse Engineering - what are we missing? Leverage off of all available surveillance solutions, break down the silos ACAMS 8 th Annual International Money Laundering Conference

23 Integration Process Detection and Prevention - continued Role of Ongoing Testing and Monitoring and Internal Audit Embedded Audit Report Systems to Detect Fraud * adapt AML surveillance models to identify anomalies, hidden relationships and other unusual incidents and patterns Review of Internal Controls - Role of Annual Compliance Report issued under FINRA Rule 3012 Review of findings beyond AML focus - learn from your peers/affiliates Escalations Process Incident Reporting Protocol central depository and resolution Training Key Risk Indicators and Trending Analysis Review filings generated from all sources, including those outside of automated surveillance AML Oversight Committee and/or Sensitive Issues Oversight Committee escalation and review process Document, document, and keep it current * Jack Sonnenschein, The RMA Journal September 2005

UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK ASSESSMENT OF CIVIL MONEY PENALTY

UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK ASSESSMENT OF CIVIL MONEY PENALTY UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK IN THE MATTER OF: ) ) Number 2015-01 Oppenheimer & Co., Inc. ) New York, NY ) ASSESSMENT OF CIVIL MONEY PENALTY

More information

DEVELOPING AN AML (ANTI-MONEY LAUNDERING) PROGRAM:

DEVELOPING AN AML (ANTI-MONEY LAUNDERING) PROGRAM: DEVELOPING AN AML (ANTI-MONEY LAUNDERING) PROGRAM: Although the Department of the Treasury has not issued specific rules for hedge funds and hedge fund managers, hedge fund managers should adopt and implement

More information

Risk Management: Integrating AML and Anti-Fraud Efforts

Risk Management: Integrating AML and Anti-Fraud Efforts Risk Management: Integrating AML and Anti-Fraud Efforts July 26, 2011 Reality Check AML and anti-fraud are necessarily intertwined the financial gain of fraudulent activity ultimately needs to be integrated

More information

2010 Mid-Atlantic Money Laundering Conference. Alma Angotti, Enforcement July 2010

2010 Mid-Atlantic Money Laundering Conference. Alma Angotti, Enforcement July 2010 2010 Mid-Atlantic Money Laundering Conference Alma Angotti, Enforcement July 2010 Master-Sub Account Arrangements General Structure: One master account with various subaccounts underneath. Several Variations

More information

AML & Mortgage Fraud Compliance Program v. 08.2013 ANTI-MONEY LAUNDERING & MORTGAGE FRAUD COMPLIANCE PROGRAM

AML & Mortgage Fraud Compliance Program v. 08.2013 ANTI-MONEY LAUNDERING & MORTGAGE FRAUD COMPLIANCE PROGRAM ANTI-MONEY LAUNDERING & MORTGAGE FRAUD COMPLIANCE PROGRAM Version: 2.0 dated 08.2013 TABLE OF CONTENTS AML & Mortgage Fraud Compliance Program 1.0 PURPOSE AND SCOPE... 3 2.0 APPLICABLE REGULATIONS AND

More information

Anti-Money Laundering Program and Suspicious Activity Reporting Requirements For Insurance Companies. Frequently Asked Questions

Anti-Money Laundering Program and Suspicious Activity Reporting Requirements For Insurance Companies. Frequently Asked Questions Anti-Money Laundering Program and Suspicious Activity Reporting Requirements For Insurance Companies Frequently Asked Questions We are providing the following Frequently Asked Questions to assist insurance

More information

BANK SECRECY ACT REQUIREMENTS FOR RESIDENTIAL MORTGAGE LOAN ORIGINATIORS: AN OVERVIEW

BANK SECRECY ACT REQUIREMENTS FOR RESIDENTIAL MORTGAGE LOAN ORIGINATIORS: AN OVERVIEW BANK SECRECY ACT REQUIREMENTS FOR RESIDENTIAL MORTGAGE LOAN ORIGINATIORS: AN OVERVIEW June 6, 2012 Marjorie A. Corwin, Esquire Gordon Feinblatt LLC 233 East Redwood Street Baltimore, Maryland 21202 410-576-4041

More information

FinCEN Issues Notice of Proposed Rulemaking that Would Extend AML Requirements to Registered Investment Advisers

FinCEN Issues Notice of Proposed Rulemaking that Would Extend AML Requirements to Registered Investment Advisers FinCEN Issues Notice of Proposed Rulemaking that Would Extend AML Requirements to Registered Investment Advisers On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN), a bureau of the US

More information

Anti-Money Laundering and Counter- Terrorism Financial Policy

Anti-Money Laundering and Counter- Terrorism Financial Policy Anti-Money Laundering and Counter- Terrorism Financial Policy Version: March 2014 1. INTRODUCTION...3 2. DEFINITIONS...3 3. RISK-BASED APPROACH...3 4. AML COMPLIANCE OFFICER...4 5. SUSPICIOUS TRANSACTION

More information

In the wake of the Madoff and Stanford Financial scandals,

In the wake of the Madoff and Stanford Financial scandals, Anti-Money Laundering Compliance: Regulators Focus on Manipulation By Bruce M. Bettigole and Christopher W. Hammond Bruce M. Bettigole is a member of Sutherland s Litigation Practice Group. He represents

More information

Presented By Greg Baldwin

Presented By Greg Baldwin ANTI-MONEY LAUNDERING COMPLIANCE OFFICER TRAINING Presented By Greg Baldwin THE ANTI-MONEY LAUNDERING COMPLIANCE OFFICER We re going to cover: Basis for the requirement to have a Compliance Officer The

More information

SFC AML/CFT Seminar Governance, PEPs & Transaction Monitoring. Philip Rodd

SFC AML/CFT Seminar Governance, PEPs & Transaction Monitoring. Philip Rodd SFC AML/CFT Seminar Governance, PEPs & Transaction Monitoring Philip Rodd Agenda Page ML/TF Vulnerabilities for the Securities Industry 3 Governance and Culture 5 PEP Identification 7 Case Study Structuring

More information

Anti-Money Laundering Facts

Anti-Money Laundering Facts Anti-Money Laundering Facts Security Benefit Life Insurance Company (SBL) has implemented a formal anti-money laundering (AML) program in response to the Financial Crimes Enforcement Network s (FinCEN)

More information

Treasury Department Proposes Anti-Money Laundering Regulations for Investment Advisers

Treasury Department Proposes Anti-Money Laundering Regulations for Investment Advisers CLIENT MEMORANDUM Treasury Department Proposes Anti-Money Laundering Regulations for Investment Advisers August 28, 2015 AUTHORS Benjamin J. Haskin Russell L. Smith Barbara Block On August 25, 2015, the

More information

EXAMINATION PRIORITIES FOR 2015

EXAMINATION PRIORITIES FOR 2015 EXAMINATION PRIORITIES FOR 2015 I. Introduction This document identifies selected 2015 examination priorities of the Office of Compliance Inspections and Examinations ( OCIE, we or our ) of the Securities

More information

Broker-Dealer Concepts

Broker-Dealer Concepts Broker-Dealer Concepts Broker-Dealer AML Program Checklist/Gap Analysis Published by the Broker-Dealer & Investment Management Regulation Group September 2011 I. GENERAL REQUIREMENTS AML AML Program Components

More information

Takeaways From Broker-Dealers Section 5 Inadequacies

Takeaways From Broker-Dealers Section 5 Inadequacies Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com Takeaways From Broker-Dealers Section 5 Inadequacies

More information

Regulatory Circular RG13-002

Regulatory Circular RG13-002 Regulatory Circular RG13-002 Date: January 2, 2013 To: Trading Permit Holders From: Department of Market Regulation RE: Anti-Money Laundering ( AML ) Compliance Program Annual Requirements for: first time

More information

Shulman Rogers Government Investigations Practice. By: Jacob S. Frenkel, Chair Date: January 13, 2016

Shulman Rogers Government Investigations Practice. By: Jacob S. Frenkel, Chair Date: January 13, 2016 Shulman Rogers Government Investigations Practice By: Jacob S. Frenkel, Chair Date: January 13, 2016 Government Investigations: White Collar Crime Worst case scenario Yes, it can end badly 2 Revolving

More information

Meeting Identity Theft Red Flags Regulations with IBM Fraud, Risk & Compliance Solutions

Meeting Identity Theft Red Flags Regulations with IBM Fraud, Risk & Compliance Solutions Leveraging Risk & Compliance for Strategic Advantage IBM Information Management software Meeting Identity Theft Red Flags Regulations with IBM Fraud, Risk & Compliance Solutions XXX Astute financial services

More information

Substantive Requirements for a Registered Investment Adviser under the U.S. Investment Advisers Act of 1940

Substantive Requirements for a Registered Investment Adviser under the U.S. Investment Advisers Act of 1940 Substantive Requirements for a Registered Investment Adviser under the U.S. Investment Advisers Act of 1940 Alternative investment fund managers and other investment advisory firms that are registered

More information

Lincoln Financial Group. FTC/SEC Red Flags Identity Theft Prevention Program

Lincoln Financial Group. FTC/SEC Red Flags Identity Theft Prevention Program Lincoln Financial Group FTC/SEC Red Flags Identity Theft Prevention Program Program Summary For Internal Use Only Table of Contents Page The Red Flags Rule 3 Key Points of the Program 4 Covered Accounts

More information

2015 FINRA and SEC Examination Priorities Summary and Comparison. January 2015

2015 FINRA and SEC Examination Priorities Summary and Comparison. January 2015 2015 FINRA and SEC Examination Priorities Summary and Comparison January 2015 Regulatory examination priorities In mid-january 2015, both the SEC and FINRA released their respective examination priorities

More information

Independent AML Testing of Introducing Broker- Dealers

Independent AML Testing of Introducing Broker- Dealers Independent AML Testing of Introducing Broker- Dealers Gina Storelli, CRCP, CAMS-Audit June 2014 Identify and describe a risk-based approach for independent testing of introducing broker-dealers in evaluating

More information

FINRA E-Learning Courses

FINRA E-Learning Courses FINRA E-Learning Courses The Definitive Source for Firm Element Training FINRA develops a wide range of e-learning courses for registered representatives, supervisors, operations staff, compliance personnel

More information

FTC FACT Act Red Flags Rule Template

FTC FACT Act Red Flags Rule Template FTC FACT Act Red Flags Rule Template Important: If you choose to use this template as a guide, you must adapt it to reflect your individual firm. Without the analysis and modification required to fit your

More information

A Critical Need: The Importance of AML Compliance for Broker-Dealers

A Critical Need: The Importance of AML Compliance for Broker-Dealers A Critical Need: The Importance of AML Compliance for Broker-Dealers AML is a FINRA Priority For broker-dealer or other financial services firms, it can sometimes appear that in order to reinforce the

More information

ANTI-MONEY LAUNDERING FOR LENDERS

ANTI-MONEY LAUNDERING FOR LENDERS ANTI-MONEY LAUNDERING FOR LENDERS Ari Karen Offit Kurman akaren@offitkurman.com 240.507.1740 Bill Heyman Offit Kurman wheyman@offitkurman.com 301.575.0393 THE RATIONALE FOR THE NEW REGULATIONS The Financial

More information

The SAR Activity Review Trends Tips & Issues

The SAR Activity Review Trends Tips & Issues The SAR Activity Review Trends Tips & Issues Issue 15 In focus: The Securities and Futures Industries Published under the auspices of the BSA Advisory Group. May 2009 Table of Contents Introduction 1 Section

More information

FFIEC BSA/AML Examination Manual. Four Key Components of a Suspicious Activity Monitoring Program

FFIEC BSA/AML Examination Manual. Four Key Components of a Suspicious Activity Monitoring Program FFIEC BSA/AML Examination Manual Four Key Components of a Suspicious Activity Monitoring Program 1 2 IDENTIFICATION OF SUSPICIOUS ACTIVITY 3 Unusual Activity Identification Employee Identification Law

More information

What Insurance Agents and Brokers Should Expect under the New Anti-Money Laundering Regulations for Life Insurance Companies

What Insurance Agents and Brokers Should Expect under the New Anti-Money Laundering Regulations for Life Insurance Companies What Insurance Agents and Brokers Should Expect under the New Anti-Money Laundering Regulations for Life Insurance Companies The USA PATRIOT Act includes provisions intended to prevent the financial services

More information

Aetna Anti-Money Laundering and Financial Sanctions Compliance Policy

Aetna Anti-Money Laundering and Financial Sanctions Compliance Policy Aetna AML and Financial Sanctions Compliance Policy Aetna Anti-Money Laundering and Financial Sanctions Compliance Policy Originating Department: Aetna s AML Compliance Office Effective Date: January 1,

More information

HIGH-RISK COUNTRIES IN AML MONITORING

HIGH-RISK COUNTRIES IN AML MONITORING HIGH-RISK COUNTRIES IN AML MONITORING ALICIA CORTEZ TABLE OF CONTENTS I. Introduction 3 II. High-Risk Countries 3 Customers 4 Products 7 Monitoring 8 Audit Considerations 8 III. Conclusion 10 IV. References

More information

Identity Theft Regulation: Are you under the SEC/CFTC microscope?

Identity Theft Regulation: Are you under the SEC/CFTC microscope? Regulatory September 2013 brief A publication of PwC s financial services regulatory practice Identity Theft Regulation: Are you under the SEC/CFTC microscope? Overview Easy access to information has made

More information

Central Oregon Community College. Identity Theft Prevention Program

Central Oregon Community College. Identity Theft Prevention Program Central Oregon Community College Identity Theft Prevention Program Effective beginning May 1, 2009 I. PROGRAM ADOPTION This program has been created to put COCC in compliance with Section 41.90 under the

More information

[Utility Name] Identity Theft Prevention Program. Effective beginning, 2008

[Utility Name] Identity Theft Prevention Program. Effective beginning, 2008 [Utility Name] Identity Theft Prevention Program Effective beginning, 2008 I. PROGRAM ADOPTION The [Utility Name] ("Utility") developed this Identity Theft Prevention Program ("Program") pursuant to the

More information

FinCEN s Proposed Anti-Money Laundering Compliance Requirements for Investment Advisers: How to Prepare Now

FinCEN s Proposed Anti-Money Laundering Compliance Requirements for Investment Advisers: How to Prepare Now FinCEN s Proposed Anti-Money Laundering Compliance Requirements for Investment Advisers: How to Prepare Now I. INTRODUCTION On August 25, 2015, the Financial Crimes Enforcement Network ( FinCEN ) proposed

More information

National Exam Risk Alert By the Office of Compliance Inspections and Examinations 1

National Exam Risk Alert By the Office of Compliance Inspections and Examinations 1 National Exam Risk Alert By the Office of Compliance Inspections and Examinations 1 In this Alert: Topic: Regulatory concerns related to master/sub-account structures. Key Takeaways: Master/sub-account

More information

2013 SEC and FINRA Year in Review for Broker Dealers and Investment Advisers

2013 SEC and FINRA Year in Review for Broker Dealers and Investment Advisers 2013 SEC and FINRA Year in Review for Broker Dealers and Investment Advisers March 27, 2014 Anne C. Flannery Jennifer L. Klass E. Andrew Southerling www.morganlewis.com Our Team Anne C. Flannery aflannery

More information

Wake Forest University. Identity Theft Prevention Program. Effective May 1, 2009

Wake Forest University. Identity Theft Prevention Program. Effective May 1, 2009 Wake Forest University Identity Theft Prevention Program Effective May 1, 2009 I. GENERAL It is the policy of Wake Forest University ( University ) to comply with the Federal Trade Commission's ( FTC )

More information

Guidance. FIN-2014-G001 Issued: February 14, 2014 Subject: BSA Expectations Regarding Marijuana-Related Businesses

Guidance. FIN-2014-G001 Issued: February 14, 2014 Subject: BSA Expectations Regarding Marijuana-Related Businesses Guidance FIN-2014-G001 Issued: February 14, 2014 Subject: BSA Expectations Regarding Marijuana-Related Businesses The Financial Crimes Enforcement Network ( FinCEN ) is issuing guidance to clarify Bank

More information

RADLEY ACURA RED FLAG IDENTITY THEFT PROTECTION PROGRAM and ADDRESS DISCREPANCY PROGRAM

RADLEY ACURA RED FLAG IDENTITY THEFT PROTECTION PROGRAM and ADDRESS DISCREPANCY PROGRAM RADLEY ACURA RED FLAG IDENTITY THEFT PROTECTION PROGRAM and ADDRESS DISCREPANCY PROGRAM SUMMARY OF OUR PROGRAM AND PROCESSES This dealership is committed to protecting its customers and itself from identity

More information

RESIDENTIAL MORTGAGE LENDERS & ORIGINATORS L COMPLIANCE PROGRAM

RESIDENTIAL MORTGAGE LENDERS & ORIGINATORS L COMPLIANCE PROGRAM RESIDENTIAL MORTGAGE LENDERS & ORIGINATORS L COMPLIANCE PROGRAM PO Box 760 Prosper, TX 75078 972 347 9921 www.americanhfm.com Contents INTRODUCTION... 6 New FinCEN Rule 31 CFR Parts 1010 and 1029... 6

More information

PORTFOLIO MANAGEMENT ASSOCIATION OF CANADA

PORTFOLIO MANAGEMENT ASSOCIATION OF CANADA PORTFOLIO MANAGEMENT ASSOCIATION OF CANADA REFERENCE GUIDE TO POLICIES AND PROCEDURES FOR PORTFOLIO MANAGERS December 2010 Introduction Compliance Systems for Portfolio Managers Regulatory Expectations

More information

CYBERSECURITY EXAMINATION SWEEP SUMMARY

CYBERSECURITY EXAMINATION SWEEP SUMMARY This Risk Alert provides summary observations from OCIE s examinations of registered broker-dealers and investment advisers, conducted under the Cybersecurity Examination Initiative, announced April 15,

More information

Client Update FinCEN Proposes Anti-Money Laundering Rules for Investment Advisers

Client Update FinCEN Proposes Anti-Money Laundering Rules for Investment Advisers 1 Client Update FinCEN Proposes Anti-Money Laundering Rules for Investment Advisers WASHINGTON, D.C. Kenneth J. Berman kjberman@debevoise.com Satish M. Kini smkini@debevoise.com Robert T. Dura rdura@debevoise.com

More information

Susan DeSantis Managing Director and Deputy Chief Compliance Officer DTCC

Susan DeSantis Managing Director and Deputy Chief Compliance Officer DTCC Microcap Fraud and Lessons from Enforcement Susan DeSantis Managing Director and Deputy Chief Compliance Officer DTCC Jim Fiebelkorn Director, Anti Money Laundering Compliance Pershing LLC, A BNY Mellon

More information

FIN-2014-A007 August 11, 2014

FIN-2014-A007 August 11, 2014 FIN-2014-A007 August 11, 2014 Advisory to U.S. Financial Institutions on Promoting a Culture of Compliance BSA/AML shortcomings have triggered recent civil and criminal enforcement actions FinCEN seeks

More information

Chatsworth Water Works Commission. Identity Theft Prevention Program. Effective beginning December 1, 2008

Chatsworth Water Works Commission. Identity Theft Prevention Program. Effective beginning December 1, 2008 Chatsworth Water Works Commission Identity Theft Prevention Program Effective beginning December 1, 2008 I. PROGRAM ADOPTION The Chatsworth Water Works Commission ("Utility") developed this Identity Theft

More information

B roker-dealers often face a significant challenge

B roker-dealers often face a significant challenge Securities Regulation & Law Report Reproduced with permission from Securities Regulation & Law Report, 44 SRLR 1410, 07/23/2012. Copyright 2012 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com

More information

Identity Theft Prevention Program. Effective beginning April 14, 2010

Identity Theft Prevention Program. Effective beginning April 14, 2010 Identity Theft Prevention Program Effective beginning April 14, 2010 PROGRAM ADOPTION Cobalt Financial Corporation ( Broker ) developed this Identity Theft Program ( Program ) pursuant to the Federal Trade

More information

FACTA Identity Theft Red Flags Program. www.chs.acfei.com

FACTA Identity Theft Red Flags Program. www.chs.acfei.com 1 FACTA Identity Theft Red Flags Program Module 1 Fair and Accurate Credit Transactions Act Overview Identity thieves use individual s personal identifiable information to open new accounts and misuse

More information

Policy: 208 Subject: Identity Theft Prevention Program Approved for Board Action: December 22, 2009 Dates Amended:

Policy: 208 Subject: Identity Theft Prevention Program Approved for Board Action: December 22, 2009 Dates Amended: Policy: 208 Subject: Identity Theft Prevention Program Approved for Board Action: December 22, 2009 Dates Amended: I. PROGRAM ADOPTION Hawkeye REC ("REC") developed this Identity Theft Prevention Program

More information

Big Data s Big Impact In Financial Investigations

Big Data s Big Impact In Financial Investigations Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com Big Data s Big Impact In Financial Investigations

More information

CATAWBA COUNTY IDENTITY THEFT RED FLAGS POLICY

CATAWBA COUNTY IDENTITY THEFT RED FLAGS POLICY UI. PROGRAM ADOPTION CATAWBA COUNTY IDENTITY THEFT RED FLAGS POLICY Catawba County s Identity Theft Prevention Program ("Program") was developed to comply with the Federal Trade Commission's Red Flags

More information

Spotting ID Theft Red Flags A Guide for FACTA Compliance. An IDology, Inc. Whitepaper

Spotting ID Theft Red Flags A Guide for FACTA Compliance. An IDology, Inc. Whitepaper Spotting ID Theft Red Flags A Guide for FACTA Compliance An IDology, Inc. Whitepaper With a November 1 st deadline looming for financial companies and creditors to comply with Sections 114 and 315 of the

More information

The Department of the Treasury established the Financial Crimes

The Department of the Treasury established the Financial Crimes Appendix A Financial Crimes Enforcement Network Programs The Department of the Treasury established the Financial Crimes Enforcement Network in April 1990. 33 FinCEN s original mission was to establish

More information

AGA Kansas City Chapter Data Analytics & Continuous Monitoring

AGA Kansas City Chapter Data Analytics & Continuous Monitoring AGA Kansas City Chapter Data Analytics & Continuous Monitoring Agenda Market Overview & Drivers for Change Key challenges that organizations face Data Analytics What is data analytics and how can it help

More information

The State of Insurance Fraud Technology. A study of insurer use, strategies and plans for anti-fraud technology

The State of Insurance Fraud Technology. A study of insurer use, strategies and plans for anti-fraud technology The State of Insurance Fraud Technology A study of insurer use, strategies and plans for anti-fraud technology September 2014 The State of Insurance Fraud Technology A study of insurer use, strategies

More information

City of Geneva. Draft Under Review Approved Obsolete. Policy Number: 1.0. April 27, 2009. Effective Date: Last Revised Date: Responsible Office:

City of Geneva. Draft Under Review Approved Obsolete. Policy Number: 1.0. April 27, 2009. Effective Date: Last Revised Date: Responsible Office: 2009 1 City of Geneva Policy Number: Effective Date: Last Revised Date: Responsible Office: 1.0 April 28, 2009 April 27, 2009 Tammy Shuttleworth Status: Draft Under Review Approved Obsolete IDENTITY THEFT

More information

CENTENARY COLLEGE POLICIES UNDER THE FAIR & ACCURATE CREDIT TRANSACTION ACT S RED FLAG RULES

CENTENARY COLLEGE POLICIES UNDER THE FAIR & ACCURATE CREDIT TRANSACTION ACT S RED FLAG RULES (FACTA) April 30, 2009 Approved by: Audit Committee of the Board of Trustees CENTENARY COLLEGE POLICIES UNDER THE A RESOLUTION ADOPTING AN IDENTITY THEFT POLICE Centenary College ( College ) developed

More information

IBN Financial Services, Inc. Identity Theft Prevention Program(ITPP) under the FTCFACTActRedFlagsRule

IBN Financial Services, Inc. Identity Theft Prevention Program(ITPP) under the FTCFACTActRedFlagsRule IBN Financial Services, Inc. Identity Theft Prevention Program(ITPP) under the FTCFACTActRedFlagsRule I. Firm Policy Our firm s policy is to protect our customers and their accounts from identity theft

More information

FRAUD EXAMINERS MANUAL (INTERNATIONAL EDITION)

FRAUD EXAMINERS MANUAL (INTERNATIONAL EDITION) TABLE OF CONTENTS SECTION 1 FINANCIAL TRANSACTIONS AND FRAUD SCHEMES ACCOUNTING CONCEPTS Accounting Basics... 1.101 Financial Statements... 1.105 International Financial Reporting Standards (IFRS)... 1.115

More information

UNIVERSITY OF MASSACHUSETTS IDENTITY THEFT PREVENTION PROGRAM

UNIVERSITY OF MASSACHUSETTS IDENTITY THEFT PREVENTION PROGRAM Doc. T08-109 Passed by the BoT 12/11/08 UNIVERSITY OF MASSACHUSETTS IDENTITY THEFT PREVENTION PROGRAM The Board recognizes that some activities of the University are subject to the provisions of the Fair

More information

Identity Theft Prevention Program

Identity Theft Prevention Program Identity Theft Prevention Program I. PROGRAM PURPOSE AND DEFINITIONS The purpose of this Identity Theft Prevention Program ( Program ) is to detect, prevent and mitigate identity theft in connection with

More information

Fraud Policy FEBRUARY 2014

Fraud Policy FEBRUARY 2014 Fraud Policy FEBRUARY 2014 TABLE OF CONTENTS 1. Application of Policy... 2 2. Purpose of Policy... 2 3. Fraud Policy... 2 4. Definition of Fraud... 2 5. Duties and Responsibilities of an Employee or Contractor...

More information

Bank Secrecy Act, Anti-Money Laundering, and Office of Foreign Assets Control

Bank Secrecy Act, Anti-Money Laundering, and Office of Foreign Assets Control Bank Secrecy Act, Anti-Money Laundering, and Office of Foreign Assets Control Overview The Bank Secrecy Act (BSA) was created in 1970 to assist in criminal, tax, and regulatory investigations. The Financial

More information

AML in a Best Practices Environment:

AML in a Best Practices Environment: AML in a Best Practices Environment: An Update on Registered dinvestment Advisers Workshop 1B January 29 th, 2014 1:00 2:15pm Catherine LaFalce (Citi) Kevin Taylor (Pershing) Alan P. Williamson (Barclays)

More information

CFTC and SEC Jointly Propose Identity Theft Rules

CFTC and SEC Jointly Propose Identity Theft Rules CLIENT MEMORANDUM March 7, 2012 CFTC and SEC Jointly Propose Identity Theft Rules Contents Identity Theft Prevention Program...1 Entities Required to Comply...1 Financial Institutions and Creditors...

More information

Policies and Procedures: IDENTITY THEFT PREVENTION

Policies and Procedures: IDENTITY THEFT PREVENTION Policies and Procedures: IDENTITY THEFT PREVENTION Section: Chapter: Policy: Compliance Administration Identity Theft Prevention I. PURPOSE The purpose of this policy is to protect patients and West Virginia

More information

FINANCIAL CRIME RISK MANAGEMENT GUIDELINE

FINANCIAL CRIME RISK MANAGEMENT GUIDELINE c FINANCIAL CRIME RISK MANAGEMENT GUIDELINE November 2011 TABLE OF CONTENTS Preamble... 3 Introduction... 4 Scope... 6 Coming into effect and updating... 7 Financial crime risks... 8 Financial crime risk

More information

Travis County Water Control & Improvement District No. 17. Identity Theft Prevention Program. Effective beginning November 20, 2008

Travis County Water Control & Improvement District No. 17. Identity Theft Prevention Program. Effective beginning November 20, 2008 Travis County Water Control & Improvement District No. 17 Identity Theft Prevention Program Effective beginning November 20, 2008 I. PROGRAM ADOPTION The Travis County Water Control and Improvement District

More information

COUNCIL POLICY NO. C-13

COUNCIL POLICY NO. C-13 COUNCIL POLICY NO. C-13 TITLE: POLICY: Identity Theft Prevention Program See attachment. REFERENCE: Salem City Council Finance Committee Report dated November 7, 2011, Agenda Item No. 3 (a) Supplants Administrative

More information

FRAUD EXAMINERS MANUAL (INTERNATIONAL EDITION)

FRAUD EXAMINERS MANUAL (INTERNATIONAL EDITION) TABLE OF CONTENTS VOLUME I SECTION 1 FINANCIAL TRANSACTIONS AND FRAUD SCHEMES ACCOUNTING CONCEPTS Accounting Basics... 1.101 Financial Statements... 1.105 Generally Accepted Accounting Principles (GAAP)...

More information

Anti-Money Laundering Policy Manual Table of Contents [Sample Client] Table of Contents

Anti-Money Laundering Policy Manual Table of Contents [Sample Client] Table of Contents Table of Contents [ Client] Table of Contents TABLE OF CONTENTS... 1 CHAPTER 1 INTRODUCTION... 3 1.1 GOALS AND OBJECTIVES... 3 1.2 REQUIRED REVIEW... 3 1.3 APPLICABILITY... 3 1.4 MONEY LAUNDERING DEFINED...

More information

The 2006 FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual:

The 2006 FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual: The 2006 FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual: Knowing the Risks Is It Possible to Keep Pace and Manage Them All? By: Carmina Hughes, Executive Director and Patricia McKeown,

More information

Integrity We are above reproach in everything we do.

Integrity We are above reproach in everything we do. Identity Theft Protection Program Compliance with FTC Red Flags Rule Approved by AHC Organizational Committee on: May 26 th, 2009 Electronic Copy Available on AHC s OIP Web Site Integrity We are above

More information

City of Hercules Hercules Municipal Utility Identity Theft Prevention Program

City of Hercules Hercules Municipal Utility Identity Theft Prevention Program City of Hercules Hercules Municipal Utility Identity Theft Prevention Program Purpose The purpose of the program is to establish an Identity Theft Prevention Program designed to detect, prevent and mitigate

More information

Green University. Identity Theft Prevention Program. Effective beginning October 31, 2008

Green University. Identity Theft Prevention Program. Effective beginning October 31, 2008 Green University Identity Theft Prevention Program Effective beginning October 31, 2008 1 I. PROGRAM ADOPTION Green University ( University ) developed this Identity Theft Prevention Program ("Program")

More information

CITY OF ANDREWS IDENTITY THEFT PREVENTION PROGRAM

CITY OF ANDREWS IDENTITY THEFT PREVENTION PROGRAM CITY OF ANDREWS IDENTITY THEFT PREVENTION PROGRAM Approved: February 26, 2010 Reviewed: March 18, 2015 I. PROGRAM ADOPTION The City of Andrews ( Utility ) developed this Identity Theft Prevention ( Program

More information

Hedge Fund. Anti-Money Laundering. The LAW REPORT. The Patriot Act Changes the Anti-Money Laundering Landscape

Hedge Fund. Anti-Money Laundering. The LAW REPORT. The Patriot Act Changes the Anti-Money Laundering Landscape hedge LAW REPORT fund law and regulation Anti-Money Laundering Do s Really Pose a Money Laundering Threat? A Decade of Regulatory False Starts Raises Questions By Michael B. Himmel and Matthew M. Oliver,

More information

CITY OF MARQUETTE, MICHIGAN CITY COMMISSION POLICY

CITY OF MARQUETTE, MICHIGAN CITY COMMISSION POLICY CITY OF MARQUETTE, MICHIGAN CITY COMMISSION POLICY Policy Number: 2008-02 Date Adopted: October 27, 2008 Department: Administrative SUBJECT: IDENTITY THEFT PREVENTION PROGRAM I. OBJECTIVE: A. To protect

More information

MTN Mobile Money 2012

MTN Mobile Money 2012 MTN Mobile Money 2012 Anti-Money Laundering It is the policy of MTN to prohibit and actively prevent the use of its money transfer services to facilitate money laundering, the funding of terrorists or

More information

Interagency Guidelines on Identity Theft Detection, Prevention, and Mitigation

Interagency Guidelines on Identity Theft Detection, Prevention, and Mitigation Guidelines to FTC Red Flag Rule(reformatted) Appendix A to Part 681 Interagency Guidelines on Identity Theft Detection, Prevention, and Mitigation Section 681.2 of this part requires each financial institution

More information

Financial Crimes Enforcement Network ( FinCen ) Rules for Non-Bank Residential Mortgage Lenders and Originators Presented to GREFPAC March 7, 2012 Therese G. (Terry) Franzen Franzén and Salzano, P.C. 40

More information

RANDOLPH COUNTY PUBLIC WORKS. Identity Theft Prevention Program. Adopted September 1, 2009 Effective beginning September 1, 2009

RANDOLPH COUNTY PUBLIC WORKS. Identity Theft Prevention Program. Adopted September 1, 2009 Effective beginning September 1, 2009 RANDOLPH COUNTY PUBLIC WORKS Identity Theft Prevention Program Adopted September 1, 2009 Effective beginning September 1, 2009 I. PROGRAM ADOPTION The Randolph County Public Works Department ( the Department

More information

Wisconsin Rural Water Association Identity Theft Prevention Program Compliance Model

Wisconsin Rural Water Association Identity Theft Prevention Program Compliance Model Wisconsin Rural Water Association Identity Theft Prevention Program Compliance Model All utilities are required to comply with this regulation. The Red Flag Rule requires any entity where there is a risk

More information

[Institution or GPLS Name] Red Flag Rules - Identity Theft/Fraud Prevention Program. Effective beginning, 2009

[Institution or GPLS Name] Red Flag Rules - Identity Theft/Fraud Prevention Program. Effective beginning, 2009 [Institution or GPLS Name] Red Flag Rules - Identity Theft/Fraud Prevention Program Effective beginning, 2009 I. PROGRAM ADOPTION The [Institution or GPLS Name] developed this Identity Theft Prevention

More information

The Florida A&M University. Identity Theft Prevention Program. Effective May 1, 2009

The Florida A&M University. Identity Theft Prevention Program. Effective May 1, 2009 The Florida A&M University Identity Theft Prevention Program Effective May 1, 2009 I. PROGRAM ADOPTION This Identity Theft Prevention Program ("Program") is established pursuant to the Federal Trade Commission's

More information

STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS SECURITIES DIVISION ) ) ) ) ) ) ) INTRODUCTION

STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS SECURITIES DIVISION ) ) ) ) ) ) ) INTRODUCTION IN THE MATTER OF DETERMINING whether there has been a violation of the Securities Act of Washington by: Ronald Newman ; Jeffrey Scott Hollingsworth ; Milestone Life Settlement Fund, LLC; Milestone Investments

More information

Fact Sheet for Financial Crimes Enforcement Network Geographic Targeting Orders for Manhattan, N.Y., and Miami-Dade County, Fla.

Fact Sheet for Financial Crimes Enforcement Network Geographic Targeting Orders for Manhattan, N.Y., and Miami-Dade County, Fla. Fact Sheet for Financial Crimes Enforcement Network Geographic Targeting Orders for Manhattan, N.Y., and Miami-Dade County, Fla. On January 13, 2016, the Financial Crimes Enforcement Network (FinCEN),

More information

FAQs Organised Crime and Anti-corruption Legislation Bill

FAQs Organised Crime and Anti-corruption Legislation Bill FAQs Organised Crime and Anti-corruption Legislation Bill What is organised crime? Organised crime normally refers to an organisation of criminals who engage in illegal activity on a large, centralised

More information

Wholesale Broker Red Flag/Identity Theft Prevention Program Certification

Wholesale Broker Red Flag/Identity Theft Prevention Program Certification Wholesale Broker Red Flag/Identity Theft Prevention Program Certification Federal regulations require that all financial institutions and their affiliates create an identity theft prevention program in

More information

PEPs and the FCPA. Presented to 10 th Puerto Rican Symposium of Anti Money Laundering. February 28 March 1, 2013

PEPs and the FCPA. Presented to 10 th Puerto Rican Symposium of Anti Money Laundering. February 28 March 1, 2013 PEPs and the FCPA Presented to 10 th Puerto Rican Symposium of Anti Money Laundering February 28 March 1, 2013 by Jay Perlman, Director Global Investigations & Compliance, Navigant Table of Contents I.

More information

University Policy: Identity Theft Prevention Policy

University Policy: Identity Theft Prevention Policy University Policy: Identity Theft Prevention Policy Policy Category: Ethics, Integrity and Legal Compliance Policies Subject: Detection, prevention and mitigation of identity theft Office Responsible for

More information

University of Nebraska - Lincoln Identity Theft Prevention Program

University of Nebraska - Lincoln Identity Theft Prevention Program I. Purpose & Scope This program was developed pursuant to the Federal Trade Commission s (FTC) Red Flag Rules promulgated pursuant to the Fair and Accurate Credit Transactions Act (the FACT Act). The University

More information

Red Flag Rules and Aging Services: What You Need to Know

Red Flag Rules and Aging Services: What You Need to Know Red Flag Rules and Aging Services: What You Need to Know Late in 2007, six federal agencies, including the Federal Trade Commission ( FTC ), jointly issued final rules and accompanying guidelines to implement

More information

Identity Theft Prevention Program

Identity Theft Prevention Program Identity Theft Prevention Program DATE: 10/22/2015 VERSION 2015-1.0 Abstract Purpose of this document is to establish an Identity Theft Prevention Program designed to detect, prevent and mitigate identity

More information

Village of Brockport Identity Theft Prevention Program Effective December 1, 2009 Confirmed 7/21/14

Village of Brockport Identity Theft Prevention Program Effective December 1, 2009 Confirmed 7/21/14 Village of Brockport Identity Theft Prevention Program Effective December 1, 2009 Confirmed 7/21/14 I. PROGRAM ADOPTION The Village of Brockport ( Village ) developed this Identity Theft Prevention Program

More information

FRD506. Financial investigation and Forensic Accounting - 30 hours. Objectives

FRD506. Financial investigation and Forensic Accounting - 30 hours. Objectives FRD506 Financial investigation and Forensic Accounting - 30 hours Objectives This course Financial Investigation and Forensic Accounting, Third Edition examines different types of offenses with a financial

More information