All courses, including the capstone course, are 4 credits. The electives are 2 credits.
The course will begin with a basic orientation to Master of Arts course, and follow with faculty presentations on research, writing, and plagiarism. Next, the course will provide an overview of what constitutes financial integrity as defined by the Financial Action Task Force (FATF) and FATF 40, which constitutes the international standard for anti-money laundering, terrorism financing, and proliferation financing. These include vulnerability assessments, customer onboarding, transaction monitoring, suspicious transaction reporting, investigation, prosecution, and asset recovery. This part of the course will therefor will focus on the FATF’s 40 Recommendations and on the Methodology for Assessing Compliance.
Instructors: R. Gordon, R. Strassfeld, P. Abramowski
This seminar begins with an introduction to the practical issues in leading a risk management group at a financial institution. Next, it will address measures that banks and other financial institutions are required to take to implement an effective preventive measures compliance program (PMCP). It will begin by reviewing international standards and US law and guidance requirements for AML/CFT programs, including policies, procedures and internal controls, the designation of an AML/CFT compliance officer, training of appropriate officers and employees, and an independent AML/CFT audit. Then it will look in detail at the two “cornerstone” elements of the internal control framework: Customer Due Diligence (CDD) and Suspicious Activity Monitoring and Reporting processes. Regulatory expectations, new developments, and common deficiencies in these areas will be discussed. The seminar will then turn to independent testing, looking at key components of this required AML program element and the increasing supervisory scrutiny in this area. What to expect from onsite examinations and communication of examination results will also be covered. Common deficiencies in such programs at every level across a variety of financial institutions and sectors. Finally, OFAC compliance requirements, program elements, and recent trends will be presented.
Instructors: W. Maddox, B. Macro, R. Delston, H. Balani, R. Strassfeld, R. Gordon, P. Abramowski
The course will examine specific problems that arise in building an effective preventive measures program. In addition to an in-depth examination of selected problems in designing and implementing preventive measures, the course will cover audits, inspections, on-site examinations, and sanctions. It will rely primarily on the presentation and discussion of case studies in each critical area of an effective compliance program, with a focus on the banking sector.
Instructors: A. Gacki, R. Gordon, J. Vivenzio, P. Deluca, R. Strassfeld, P. Abramowski; Secondary - R. Small, J. Wagner, D. Stipano, J. Smith
This course will examine the operations of national financial intelligence units in analyzing suspicious activity reports and other data and information and in creating actionable intelligence from that information. It will then review the investigation and prosecution of both criminal and civil prosecution of financial integrity crimes. The course will also review the FATF operational and law enforcement standards and methods of compliance assessments. A sampling of key national laws and regulations, including those of the United States, will be included.
Instructors: B. Stevenson, K. Goepp, D. Lormel, E. van der Does de Willebois, R. Gordon, R. Strassfeld, P.Abramowski, R. McDonell
The course will examine specific problems that arise in building and prosecuting financial integrity cases. In addition to an in-depth examination of selected problems in building and prosecuting cases, the course will cover problems in asset tracing and recovery, and will rely primarily on the presentation and discussion of case studies in each critical area of investigation and prosecution.
Instructors: K. Goepp, B. Stevenson, D. Lormel, A. Angotti, P. Abramowski, E. Lafferty, R. Gordon, R. Strassfeld
This course will examine in detail how financial intelligence units, investigators, prosecutors, and investigative judges/magistrates cooperate with officials of other jurisdictions in identifying possible financial integrity crimes, investigating and prosecuting those cases, and recovering assets that are candidates for freezing or confiscation. The course will also review the FATF standards for cooperation in civil and criminal matters and methods of compliance assessments, relevant U.N. conventions, model laws and regulations, and a sampling of key national laws and regulations, including those of the United States.
Primary - J. Brun, E. van der Does de Willebois, J. Nandeau, R. Gordon, R. Strassfeld, R. McDonell, A. Angotti
Secondary - J Nadeau, S. Eckert, J. Myers, G. Peterson, T. Steinberg
This course will consider the use of automated customer acceptance and transaction monitoring systems, as well as follow-up investigations by internal FIUs. It will examine key issues in data base formation, including web-based text recognition and analysis, link analysis, and different forms of statistical discriminant and regression analysis, and forms of data presentation. The course will examine current vendor products. The course will also make use of case studies.
Instructors: Phil Deluca, Rick Small, Dan Stipano, Jim Vivenzio, Alma Angotti, Pawneet Abramowski, Richard Gordon, Robert Strassfeld
This course will consider the use of automated systems for analyzing suspicious transaction reports and other data to develop actionable intelligence, as well as follow-up investigations by national FIUs. It will examine key issues in data base formation, including web-based text recognition and analysis, link analysis, and different forms of statistical discriminant and regression analysis, and forms of intelligence presentation. The course will examine current vendor products. The course will also make use of case studies.
Instructors: Braddock Stevenson, Katherine Goepp, Pawneet Abramowski, Gary Peterson, Richard Gordon, Robert Strassfeld
The course will cover the process of assessment compliance with the Financial Action Task Force's 40 Recommendations by use of the FATF's Methodology of Assessment. It will include all aspects of compliance assessment, from initial self-assessment questionnaire preparation to final discussion of the draft assessment at the FATF/FSRB Plenary.
Instructors: Richard Gordon, Rick McDonell, Nadim Kyriakos-Saad, Josée Nadeau, Emile van der Does de Willebois, Robert Strassfeld
The course will focus on practical and theoretical issues of global justice as they pertain to anti-money laundering and combating the financing of terrorism. What are our obligations to international justice? How do they influence financial integrity law law? The course will consider the normative basis of jurisprudence, comparing legal positivism to natural law theory. Next, the course will look at theories of global justice suitable to answer normative questions on what law should aim at. The remainder of the course will consider practical issues that come into play with financial integrity law, such as corruption, poverty, distributive justice, human rights, violence, and war.
Instructors: Richard Gordon, Mike Benza, Phil Deluca, Ellen Lafferty, Robert Strassfeld, Sue Eckert
This course will cover the rise of technology use in compliance and risk disciplines impacting financial crimes industry. The focus will be on use of artificial intelligence and introduction of new products such as cryptocurrency, initial coin offerings and crypto asset backed offerings lend to increase complexity in the role of compliance when dealing with products and technology without an established roadmap. Content and discussions will examine the changing demands on compliance officers and growing reliance of technology in operational execution of the AML/CFT program. It will review the disparate guidance globally which make the operational implementation and compliance advisory challenging in a fast-paced financial services industry. The takeaway will be to ensure that students are able to apply financial integrity principals as they navigate through the innovative stages.