Money Transfer Agents: Know Your Customers!
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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.
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Money Transfer Agents: Know Your Customers!
- 1. 2014 Consumer Protection & Compliance Conference Agents: Know Your Customers!
- 2. Consumer Protection & Compliance Conference 2014 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 Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
- 3. Consumer Protection & Compliance Conference 2014 Suspicious Activity • Prevent • Detect • Report • Assist Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
- 4. Consumer Protection & Compliance Conference 2014 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 Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
- 5. Consumer Protection & Compliance Conference 2014 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 Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved. 5
- 6. Consumer Protection & Compliance Conference 2014 Customer Identification Program Establishing a reasonable basis to believe person is who he/she claims to be Mickey Mouse? Elvis Presley? (I think not….) Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved. 6
- 7. Consumer Protection & Compliance Conference 2014 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”? Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved. 7
- 8. Consumer Protection & Compliance Conference 2014 Solid Understanding of Market Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved. 8
- 9. Consumer Protection & Compliance Conference 2014 What is normal & expected? Socio - Economic profile occupation education income ethnicity dress speech patterns Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
- 10. Consumer Protection & Compliance Conference 2014 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? Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved. 10 What is normal & expected?
- 11. Consumer Protection & Compliance Conference 2014 Good Customer Interface Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved. 11
- 12. 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 12
- 13. 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 13
- 14. 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 14
- 15. Consumer Protection & Compliance Conference 2014 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? Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved. 15
- 16. Consumer Protection & Compliance Conference 2014 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? Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved. 16
- 17. Consumer Protection & Compliance Conference 2014 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 Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
- 18. Consumer Protection & Compliance Conference 2014 Training - Ongoing Training – not just once a year can’t set it and forget it do risk based refreshers throughout year Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
- 19. Consumer Protection & Compliance Conference 2014 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 Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
- 20. Consumer Protection & Compliance Conference 2014 Front Line Fraud Protection Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
- 21. Consumer Protection & Compliance Conference 2014 Elder Abuse Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
- 22. Consumer Protection & Compliance Conference 2014 Human Trafficking Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved.
- 23. Consumer Protection & Compliance Conference 2014 Drug Trafficking Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved. 23
- 24. Consumer Protection & Compliance Conference 2014 Thank you Western Union Confidential | ©2014 Western Union Holdings, Inc. All Rights Reserved. 24 Jay Postma, CAMS President MSB Compliance Inc. Jay.Postma@MSBComplianceInc.c om John Schmarkey, CAMS, CFE BSA/AML Compliance Specialist MSB Compliance Inc. John.Schmarkey@MSBComplianceInc.com www.MSBComplianceInc.com www.Twitter.com/MSBCompliance Weekly newsletter: paper.MSBComplianceInc.com