money transfer agents: know your customers!
DESCRIPTION
September 16, 2014 presentation by John Schmarkey, CAMS, CFE and Jay Postma, CAMS, before Western Union's 2014 Consumer Protection & Compliance Conference. Covering BSA/AML, Culture of Compliance, Know Your Customer, Customer Identification Program, Customer Due Diligence, Socio-Economic profiling, Socio-Pathic profiling, etc.TRANSCRIPT
Agents: Know Your Customers!
2014 Consumer Protection & Compliance Conference
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Objectives
Enhance risk management practices to better mitigate risks
Protect business and make it more profitable
Protect and serve your community – be a good citizen
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Suspicious Activity
• Prevent• Detect• Report• Assist
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Culture of Compliance
Signs of a lax, Non-Compliance Culture?
FinCEN’s Culture guidance – FIN-2014-A007
Advisory to U.S. Financial Institutions on Promoting a Culture of Compliance
Engaged Leadership
Compliance not compromised by revenue interests
Appropriate internal information sharing
Adequate Human and Technological Resources
Effective Program- Independent, Competent Testing
Understand importance, utility of reporting
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Hard Target OR Soft Pushover
Do not compromise yourself
with exceptions
poor documentation
lack of focus or willpower
Will you be a wet noodle? Man or Mouse?
Official government ID - real, current
not expired
not international driver’s licenses
not “for novelty purpose only” ID cards
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Customer Identification ProgramEstablishing a reasonable basis to believe person is who he/she claims to be
Mickey Mouse? Elvis Presley? (I think not….)
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
What does KYC look like?
Before you can Know Your Customer, you need to know your market.
How do I recognize a customer when I see him/her?
How do I distinguish a person coming in to buy something that I don’t want to be a “customer”?
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Solid Understanding of Market
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
What is normal & expected?
Socio - Economic profile
occupation
education
income
ethnicity
dress
speech patterns
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Socio-pathic profile
prevalent problems and issues in our neighborhood
familiarity with types of people who may be
perpetrating crimes in our neighborhood
familiarity with types of victims locally
Who is being taken advantage of in our
community?
What is normal & expected?
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Good Customer Interface
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
STOP!
Don’t be distracted
Make eye contact
Pay attention
Be alert
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Look!
Be observant
Really look (not just see)
Observe demeanor
Detect signs of deception
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Listen
Clear questions and answers
non-threatening
casual alertness
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Who is this person?
Be friendly- you want customers to come back
Details- employment, occupation, title, where
other identifiers
does person actually live/work nearby?
family, friends, business associates, related customers
What might that tell us?
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
What services?
Used, inquired about
Cross selling is good business practice
helps understand customer too
may also help identify red flags
Does person meet profile of what is expected for market?
Does timing, frequency of transactions make sense?
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Levels of Knowing
New customer – simple remittance
Repeat remittance customer
Detailed information gathered from multiple tranx types
No interaction
Moderate interaction
Closely held, limited openness
Too open
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Training - Ongoing
Training –
not just once a year
can’t set it and forget it
do risk based refreshers throughout year
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Role Playing
Isn’t role playing just another way of…
inspect what you expect?
Allows you to demonstrate how to handle real life
scenarios effectively
Mystery shopping can help prove whether training is
effective or not
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2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Front Line Fraud Protection
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2014
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Elder Abuse
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Human Trafficking
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2014
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Drug Trafficking
Consumer Protection & Compliance Conference
2014
Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
Thank you
Jay Postma, CAMSPresidentMSB Compliance [email protected]
John Schmarkey, CAMS, CFEBSA/AML Compliance SpecialistMSB Compliance [email protected]
www.MSBComplianceInc.comwww.Twitter.com/MSBCompliance
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