Pub. 15 2020-2021 Issue 4

NEBRASKA BANKERS ASSOCIATION 19 Bridgepoint provides confidential institutional investment banking services delivered by local professionals. • Distressed and bridge financing (equity and non-bank finance) • Capital raising for growth or liquidity • Sell-side M&A advisory services for banks and operating companies • Leveraged finance solutions for community banks • Generous fee-sharing program for bankers CREATIVE SOLUTIONS THAT LEAD TO OPTIMAL RESULTS OFFICES: Omaha • Lincoln • Des Moines • Denver • Chicago NEBRASKA PRINCIPALS: Matt Plooster • Gary Grote Wm. Lee Merritt • Mike Anderson Call Bridgepoint Investment Banking Today 402-817-7900 www.bridgepointib.com [ Securities offered through an unaffiliated entity, M&A Securities Group, Inc., member FINRA/SIPC “Bridgepoint is a true resource and partner for commercial bankers as we all work through one of the most trying years in history. We’re here for you when your clients need creative financial solutions.” – Gary Grote Managing Director • Investment Scams – The U.S. Securities and Exchange Commission (SEC) urged investors to be wary of COVID-19-related investment scams, such as promo- tions that falsely claim that the products or services of publicly traded companies can prevent, detect or cure coronavirus. • Product Scams – The U.S. Federal Trade Commission (FTC) and U.S. Food and Drug Administration (FDA) have issued public statements and warning letters to companies selling unapproved or misbranded products that make false health claims pertaining to COVID-19. Additionally, FinCEN has received reports regarding fraudulent marketing of COVID-19-related supplies, such as certain facemasks. • Insider Trading – FinCEN has received reports re - garding suspected COVID-19-related insider trading. When you throw in the reminder regarding the impor - tance of detecting trends related to COVID-19 medical fraud, imposter scams and cyber-enabled crime, the bank- ing industry has the daunting task of being the watchdog for fraudulent transactions. Where do we start? Beginwith the bank’s system for identi - fying potentially suspicious activity. Most banks havemultiple channels that funnel unusual activity to the appropriate party for research and reporting. First, and likely most important, bank employee detection is key. During the course of day-to-day operations, employees may observe unusual or potentially suspicious transaction activity or requests. During this pandemic, it is important em- ployees are aware of the FinCEN emerging trends so they can be aware of potential red flags that may be uncovered. Further, it would be appropriate to share the bank’s own specific un - usual activity trends, if any are identified based on the bank’s customers, products and services, and geographic location. Second, monitoring systems are designed to detect po- tential suspicious activity whether manual or automated. For manual monitoring, the goal is usually to identify higher-risk transactions, such as those involving large amounts of cash or those to or from certain geographies, which may need to be tweaked when considering the current FinCEN emerging trends relating to the coronavirus. Automated accountmonitoring systems can certainlymake it easier toidentify individual transactions,patternsofunusual activ- ity, ordeviations fromexpectedactivity.Thesesystemscancapture a wide range of account activity, such as deposits, withdrawals, funds transfers, automated clearing house (ACH) transactions, and automated teller machine (ATM) transactions, directly from the bank’s core data processing system. However, the program parameters and filters should be reasonable and tailored to the activity that the bank is trying to identify or control andmay need some fine-tuning based on our current COVID-19 environment. Compliance Alliance — continued on page 20