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Survey Question of the Week Results
What is your progress on developing your ID Theft Prevention Program?
Institution Size < $100M $100-$500M $500M-$2B Over $2B Totals
We have implemented a Board approved program and have conducted employee training on it 2 7 3 4 16 (4.9%)
We have a Board approved program, but have not finished implementation or training 2 5 0 1 8 (2.5%)
We have finished our risk and controls analysis, and are preparing program for Board approval 1 10 19 12 42 (13.0%)
We are in the process of our risk and controls analysis 15 57 51 54 177 (54.6%)
We have not started our analysis 18 46 12 5 81 (25.0%)
Totals 38 125 85 76 324 (100%)


  • FinCEN Strategic Plan for FY 2008-2012 (5/8/08)
    The Financial Crimes Enforcement Network (FinCEN) released Strategic Plan for 2008-2012, outlining FinCEN's goals for the next five years.  Among its goals include: financial systems resistant to abuse by money launderers, terrorists and their financial supporters; detection and deterrence of money laundering, terrorism financing and other illicit activity; and efficient management, safeguarding, and use of BSA information.
  • Wolfsberg Group Updates FAQs on Politically Exposed Persons (5/7/08)
    The Wolfsberg Group updated its 2003 Frequently Asked Questions (FAQs) on Politically Exposed Persons ("PEPs").  The revised edition reinforces the position that only individuals holding senior, prominent or important positions with substantial authority over policy, operations or the use or allocation of government-owned resources can be PEPs (and that "Close Associates" and "Close Family" of PEPs should be included in the control framework for PEPs).  The FAQs also include guidance on assessing whether an individual is a PEP; managing PEP relationships other than in a private banking context; dealing with PEP involvement in operating companies and state owned enterprises; and managing individuals and related entities once the reason for their PEP designation is no longer applicable.
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