Combating Real Estate Financial Crimes

The Bank Secrecy Act and Anti-Money Laundering Act remain a top priority for bank regulators. Virtually all large U.S. banks are or recently have been under enforcement actions for BSA/AML violations.

Federal and state authorities including the OCC, FDIC, NYDFS, DOJ, FinCEN, SEC, FINRA and OFAC pursue enforcement actions. This enforcement is not expected to diminish in the Biden Administration. 

Bruce Oliver

“This is complicated stuff. There is a lot of risk involved and it’s easy to get it wrong,” said Bruce Oliver, Associate Vice President of CREF Policy with the Mortgage Bankers Association. “And if a person gets it wrong, there is both compliance risk and reputational risk, so you really do not want to be in that position.”

Oliver will moderate a panel discussion, Multifamily Real Estate Financial Crimes Training, on Wednesday, March 10. The webinar is free to MBA members and $399 for non-members.

“Ongoing training on compliance issues is a core component of any financial institution’s compliance risk-management framework,” Oliver said. He noted anti-financial crime training is available elsewhere outside of the mortgage context, but said this event is specifically designed for anyone engaged in commercial or multifamily mortgages.

“We’ve pulled together a great team of people to present, including Dan Stipano, Partner at Davis Polk & Wardwell, who is a longtime OCC supervisor now in private practice. He brings perspective from inside the agency as well as advising clients,” Oliver said. “Freddie Mac Vice President of Operational Risk Michael Kenney will give the GSE perspective and PGIM Real Estate Finance Director of Compliance Patrick Caughey and M&T Bank Administrative Vice President Melissa Prohaska will represent the lender compliance perspective.” 

Webinar participants will learn about the elements of mortgage fraud, money laundering and restrictions under economic and trade sanctions. The five pillars of the anti-money laundering program and how to spot suspicious “red flags” will also be discussed.