Compliance Professional Resources    David DeMartino    212.257.6500 ext.1    ddemartino@compliancepros.net 


September 2011   
This issue's articles:

A Revolutionary Customer On-Boarding Solution Designed for Financial Institutions (Int'l and Domestic)
CISADA Regulations
Compliance and Human Resources Updates
How is the Market?
Regulator's Corner

 
A Revolutionary Customer On-Boarding solution designed for Financial Institutions (Int'l and Domestic)


Compliance Professional Resources, LLC and AML Partners, LLC announce an agreement to promote AML Partners' revolutionary new Customer On-Boarding software solution.

New York, New York. / PRBuzz.com / September 14, 2011—Compliance Professional Resources, LLC and AML Partners, LLC recently agreed to a strategic relationship that authorizes CPR to distribute AML Partners' cutting-edge anti-money-laundering technology for financial institutions. CPR will also provision deployment specialists specific to AML Partners' newly released SURETY-CDD© product.

SURETY-CDD© provides to financial institutions a powerhouse tool to maximize the effectiveness and efficiency of customer due-diligence efforts and to analyze enhanced due-diligence information of potential customers during new-client on-boarding procedures. SURETY-CDD©, a technology solution that resulted from expertise gleaned over 20 years of successful on-site consulting, features in-house customization, ease of use, and unparalleled compliance tracking and reporting.

David DeMartino, managing partner of CPR, lauded the advance in compliance software and its tremendous impact on financial institutions' efforts to successfully comply with customer due-diligence requirements: "The SURETY-CDD© solution is now the leading technology in the CDD and customer on-boarding arena."

Frank Cummings, co-founder and CEO of AML Partners, said the strategic relationship with CPR is a value-added solution for banks in their on-boarding and compliance efforts. "CPR brings the top talent in the compliance industry to bear on the ever-evolving complexities of on-boarding," Cummings said.

Len Adams, managing partner of CPR, concluded, "The combination of AML Partners' SURETY-CDD© product and CPR's deployment specialists make for a very strong team in the on-boarding space."

About Compliance Professional Resources
CPR (www.compliancepros.net, a regulatory compliance-services firm, provides a unique blend of compliance staff augmentation and compliance consulting services. According to DeMartino, CPR features managing partners that have essentially pioneered the industry, making his firm the clear leader in the Regulatory Compliance service space.

"Our commitment to excellence in all phases of our business is unparalleled," DeMartino said. "As it relates to recruiting, we will provide you with the best most skilled candidates; we work tirelessly to get the right person after we completely understand your needs. Our compliance consultant services are surgically focused on getting the job done as expeditiously as possible, and without crippling your budget. We only provide seasoned and experienced consultants, always with the correct skill sets. Our goal is to get it right the first time."

About AML Partners
AML Partners (www.amlpartners.com) is a behavioral-risk mitigation firm specializing in anti-money laundering and counter-terrorism financing consulting and software development for financial institutions.

For more information regarding the SURETY-CDD©solution or to arrange a demonstration, please contact Dave DeMartino at 212-257-6500 or ddemartino@compliancepros.net.


 
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CISADA Regulations


by David DeMartino, CPC
Managing Partner, Compliance Professional Resources, LLC


Regulations cover sanctions and activities under the Iran Sanctions Act of 1996. CISADA has recently expanded the scope of sanctions from the pre-existing sanctions which include:
  • Denial of US export licenses
  • Denial of certain loans from US financial institutions
  • Prohibitions on a sanctioned person
  • Banned from receiving US contracts
  • Restricts imports in accordance with IEEPA
  • Denial of export-import bank assistance for exports

New restrictions which were issued last August are focusing on greater scrutiny by the Treasury Department on Correspondent Banking activity. The Iranian Financial Sanctions Regulations require that the US Treasury Department either prohibit or place strict conditions on the establishment of correspondent or payable-through accounts in the US of a foreign financial institution that knowingly has or is believed to have:
  • Facilitated the activities of a blocked person under UN Security Council resolutions
  • Engaged in money laundering to carry out any of the above activities
  • Facilitated the efforts of the Central Bank of Iran to carry out of the above activities


  • Provided or facilitated significant transactions or provided significant financial services to any blocked or sanctioned agents or affiliations with Iran
  • Facilitated the efforts of the Government of Iran to acquire WMD or delivery systems for the same to support any Foreign Terrorist Organization
We believe the last restriction will allow for broad interpretation by the regulators of how each financial institution has interpreted and reviewed its activity to ensure there is no evidence of dealing with this business type.

In an effort to demonstrate compliance to recent regulations and proactive management review, CPR, in conjunction with the Madison Consulting Group, has developed a methodology to review correspondent banking activity to identify potential clients, affiliates and or transactions which might be viewed as high risk by US Regulators.

Given our significant work in AML transaction reviews, KYC and client risk model development, we believe that some of our financial tools, database and analytics can be leveraged to perform both top down and bottom up review of client data to detect CISADA violations.


 
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Compliance and Human Resources Updates


by David DeMartino, CPC
Managing Partner, Compliance Professional Resources, LLC

I wanted to tell you about a few unique items that may be of interest to you, specific to compliance and human resources.

1. CPR has enhanced its website and we now include a Salary Guide and Relocation Expense Calculator for you to use at no cost. Thus, you can evaluate compliance salaries and cost of living expenses.
Find out more »

2. We now send out quarterly regulatory updates and zero in on the issues that will have an effect on compliance and human resources.
See below »

3. At any time, you can pose a question in our web site's Ask the Expert section if you have a compliance related questions.
Find out more »

4. Our quarterly newsletter is packed full of both industry compliance issues and HR related issues. If you do not get the newsletter, please sign up. We also have an archive of past newsletters.
Find out more »

5. We offer a great Compliance on Demand service.
Find out more »

Skilled compliance professionals are becoming difficult to find. With the economy still stalling, one would wonder why it is becoming so difficult to find skilled compliance resources these days.

       
Certainly, compliance organizations were impacted by the effects of the recession. Staffing cuts, freezes to the expansion of resources, and cuts in budgets all tended to inhibit growth in the compliance market. However, we are a few years into the worst of the recession and the need to address compliance issues and projects is now essential.

Also, the regulators have been very aggressive, resulting in MOU's, enforcement actions and negative comments on reviews. This has resulted in the pool of available resources being greatly diminished.

Thus the days of a glut of skilled compliance professionals seems to have waned. Now the ability to find very skilled talent in the space easily is essentially over. The need to find professional compliance skills should be addressed with reliable compliance staffing firms and CPR has tremendous depth in this area; we helped to pioneer the compliance space.

Please keep in mind that we are experts in the STAFFING AND RECRUITING of compliance personnel. We have a long history of helping to pioneer the compliance technology and regulatory arena and we bring that expertise to all aspects of compliance staffing. We can staff for the most difficult to fill staffing requirements in the risk and compliance market. Our staff are proven experts. Our relationships with compliance professionals are second to none.

 
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How's the Market?


by Len Adams, C.P.C.
Chief Executive Officer Adams Consulting Group, LLC
Managing Partner, Compliance Professional Resources, LLC
Managing Partner, The A.R.D. Group


How's the market?

This is a question that I am asked almost daily by both employer clients and candidates. I would like to take a few moments to discuss the state of the job market, from an employer's viewpoint specific to the world of compliance. In the next CPR newsletter, I will comment from the candidate viewpoint.

As I write this in September of 2011, we have been through one of the worst economic downturns that any of us can remember. Throughout the downturn and in the current market, the demand for compliance professionals has remained strong. Yes, we had some pockets of time during the last couple of years where there appeared to be less activity in hiring; however, overall, the job market remained relatively fluid. This is due to a number of factors.

First and foremost, the regulatory compliance environment is constant. Financial institutions, faced with ever increasing scrutiny, oftentimes need to expand their compliance staff, or sometimes need to make changes to their compliance staff at various levels. Changes such as this are generally recession proof. Thus, from an employer's viewpoint, there continues to be movement in the compliance market. Due to the constant demand for skilled professionals, coupled with a number of current long-term projects (fueled by several large scale regulatory issues at several institutions), the availability of well-rounded professionals is becoming difficult; although not impossible.

As an employer seeking to staff an interim project due to a regulatory issue, or seeking to add or replace members of their compliance team, there are several suggestions I could make to be successful:

1. With regard to staffing a project, be aware that there is a great deal of rate sensitivity today because of the competitive market.

2. When preparing to staff a project, be ready to pull the trigger. Again, due to competitive nature of the business today, projects are being staffed quickly. Consultants will go to the first and best offer...the market today is very different than it was several years ago.

3. Be realistic about the length of the project. If you envision it to be a 3-month project, say so. Don't overestimate and call it "open ended" That is not fair to you or the prospective consultant.

4. Be diligent in who you are engaging. Make sure that the consultants you are bringing in have solid knowledge and clean backgrounds. Too many times we see people hanging out a shingle as a professional compliance consultant or consulting firm with no real extensive knowledge or contacts in the industry. You do not want someone coming with "baggage."

With regard to full time hires, please keep the following in mind:

1. If you are replacing or adding to staff, develop a concise, clear and realistic position description. Be specific in what type of skill set you need.

2. Be realistic with your compensation levels. Speak with peers in the industry, recruiters, etc, to determine what candidates are being paid in the marketplace. Just because you are replacing someone who has been with your institution for 10 years and was making $X, don't assume that that is what a replacement candidate will cost in today's market. The flip side of the coin is - don't feel that you need to overpay either. We always suggest to clients that the market doesn't lie...it is very easy to get a sense for what a position is worth just by virtue of the comp level of qualified candidates. If your range is $40K less than three of the last qualified candidates that you have identified, than you either need to raise your range or lower your expectations.

3. Go out to the market when you are ready to hire. From a reputational risk viewpoint, there is nothing more damaging to the successful execution of a search than for a position to be open too long. It does scare prospective candidates away.

In summary, the good news is that the compliance field is one of the fastest growing areas in the financial industry today. This strong growth means while the demand may create some pockets of difficulty due to shortages of talent, the long term prospect for the industry is strong, since it is attracting large numbers of candidates into the field, both by virtue of cross trained employees with broad skill sets, as well as university graduates with strong desire to be part of the industry.


 
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Guidance to Financial Institutions on Recent Events in Syria
Find out more »

FinCEN today released a final rule, "Definitions and Other Regulations Relating to Money Services Businesses," that more clearly defines which businesses qualify as MSBs and are therefore subject to anti-money laundering rules under the Bank Secrecy Act.
Find out more »

Withdrawal of the Finding of Primary Money Laundering Concern and the Final Rule against VEF Banka. (As submitted to the Federal Register)
Find out more »

Regulator's   
Corner   


Guidance to Financial Institutions on the Commercial Bank of Syria
Find out more »

The Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, and the State of Florida Office of Financial Regulation Assess Civil Money Penalties Against Ocean Bank
Find out more »


 
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About CPR

CPR is a unique regulatory compliance services firm. A unique blend of compliance recruiting services (executive, permanent, and temporary), and compliance consulting services. Add in managing partners that have essentially pioneered the industry, this makes CPR clearly a leader in the Regulatory Compliance service space.

Our commitment to excellence in all phases of our business is unparalleled. As it relates to recruiting, we will provide you with the best, most skilled candidates, we work tirelessly to get the right person, after we completely understand your needs. Our Compliance consultant services are surgically focused on getting the job done as expeditiously as possible, and without crippling your budget.

We only provide seasoned and experienced consultants, always with the correct skill sets. Our goal is to get it right the first time.


www.compliancepros.net