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Advanced Due Diligence: A Cornerstone of any BSA/AML Program


Gain valuable insight into advanced due diligence and the requirements of risk-based customer due diligence.

The Bank Secrecy Act (BSA), as amended by the USA PATRIOT Act (PATRIOT Act), requires financial institutions, including banks, credit unions, broker-dealers, and money services businesses (MSBs), to develop and implement anti-money laundering (AML) compliance programs. FinCEN has recently issued final rules under the BSA to clarify the four core elements of customer due diligence (CDD) and to strengthen requirements, including by introducing new rules for identifying and verifying the identities of beneficial owners of legal entity customers. This topic will provide important updates on the new legal requirements as well as an in-depth look at the elements of a sound CDD program from initial due diligence to ongoing monitoring to escalating and reporting. This topic is critically important for ensuring that your customers are properly risk assessed and for avoiding regulatory criticism of your compliance program.



Stephanie R. Hager

Stephanie R. Hager

Stevens & Lee

  • Associate with the law firm of Stevens & Lee
  • Represents financial institutions and other public companies in a wide range of corporate matters, including capital formation, mergers and acquisitions, corporate governance, reporting requirements under the Securities Exchange Act of 193,4 and financial institution regulatory requirements under banking and securities law
  • Wide range of international experience
  • Member of various associations and a published author
  • LL.M. degree, University College London; J.D. degree, Washington & Lee University School of Law; B.A. degree, magna cum laude, Allegheny College
Steven Szaroleta

Steven Szaroleta


  • Director, Investigations, Disputes, and Risk at AlixPartners
  • Over 15 years of experience performing compliance assessments, internal audits, regulatory monitorships, forensic accounting reviews, and complex international investigations related to compliance with the U.S. Foreign Corrupt Practices Act as well as Bank Security Act/Anti-Money Laundering Regulations
  • Has conducted FCPA investigations for global financial institutions related to bribery, corruption, fraud, and misconduct
  • Has a deep understanding of regulatory risks as they relate to customers and transactions, geographies and delivery channel, and a variety of products and services
  • Certified fraud examiner and certified anti-money laundering specialist
  • M.B.A. degree, University of Delaware; B.S degree, Villanova University

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