Networking Breakfast and Registration

Opening Remarks from the Co-Chairs

Sandra Calmes
Vice President, Senior Corporate Counsel & Global Financial Crimes Officer
Liberty Mutual Insurance

Luis Duarte de Jesus
Head of U.S. Anti-Financial Crimes, OFAC and Sanctions Compliance Lead
Generali

OFAC Presentation

Keeping Up with Russia Sanctions:

Unravelling Key Developments and New, Wide-Reaching Russia Sanctions Impacting the Insurance Industry

Richard McDermott
Global Sanctions Program Director
AmTrust Financial Services

Dana Cordes
AVP, Financial Crimes Compliance
MetLife

As the U.S. continues to impose severe and far-reaching economic sanctions on Russia, insurers must keep up with a barrage of new rules. The rapidly changing sanctions regime signals an urgent need for firms and companies to ensure processes are robust and that proper due diligence is in place.

Given the potential legal and financial consequences related to a raft of challenges from sanctions targeting Russia, insurance and reinsurance companies must unravel a complex web of unprecedented and rapidly changing economic sanctions. During this panel, we will explore key areas including:

• Implementing robust processes to ensure proper due diligence
• Navigating key differences between US, UK, and EU restrictions
• Ensuring risk-based compliance programs in response to expansive use of sanctions and new methods of evasion
• Navigating challenges related to the Russian Oil Price Cap for insurers
• Understanding the expansive scope and targets for the latest sanctions

Networking Break

Exploring Key Uses and Risks of AI in BSA/AML Compliance:

Opportunities and Challenges for Insurance Companies

Luis Duarte de Jesus
Head of U.S. Anti-Financial Crimes, OFAC and Sanctions Compliance Lead
Generali

Michael Heffernan
Director, Global Financial Crimes
Liberty Mutual Insurance

AI and emerging technologies are ushering in a new era of efficiency and effectiveness for compliance in the insurance sector. During this panel, we will explore the myriad ways that AI and other emerging technologies are reshaping AML compliance in the insurance industry through increased risk assessment precision, real-time monitoring, automating reporting, adaptive compliance, and a host of other solutions. During this panel, we will explore:

• Leveraging AI-driven technologies to quickly detect fraud and AML risk
• Using AI for advanced risk assessment to assess customer risk profiles
• Implementing real-time transaction monitoring
• Streamlining complex reporting requirements
• Ensuring accurate and timely regulatory submissions

Sanctions Evasion and Circumvention:

Practical Guidance for Companies to Detect and Prevent the Circumvention of Sanctions and Being Prepared for the Newest, Most-Sophisticated Techniques

Sandra Calmes
Vice President, Senior Corporate Counsel & Global Financial Crimes Officer
Liberty Mutual Insurance

Evanthia Coffee
Senior Lawyer
Gard AS

An evolution in evasion techniques means a new wave of compliance risks for financial institutions and the wider industry, requiring robust adaptation and constant vigilance. Our expert panel will examine what constitutes sanctions evasion/circumvention, the current landscape of evasion threats, risks, and typologies, and practical tips for identifying them and being prepared, including:

• Assessing the current landscape of sanctions evasion risks and typologies
• Key methods for detecting and preventing circumvention of sanctions
• Best practices for carrying out risk assessments and sanctions compliance
• Identifying indications of circumvention of sanctions through third countries Understanding the new efforts to prosecute sanctions evasion

Networking Luncheon

Strengthening Your Sanctions Screening Program:

Components of an Effective, Risk-based Sanctions and Export Compliance Program and Guidance on Updated OFAC Requirements

Andrew Gifford
General Counsel and Secretary
General Re

Kelvin Miller
Senior Counsel, Legal Shared Services, Economic & Trade Sanctions
Travelers

Isabella Stengele
Global AML/Sanctions Project Leader, U.S. Financial Crimes Team
Arthur J. Gallagher
(WSN Member)

Enhancing the effectiveness of your sanctions screening program is critical in today’s stringent regulatory landscape. This entails robust due diligence processes, continuous monitoring, and the implementation of state-of-the-art screening tools and technologies. Strengthening your sanctions screening program not only safeguards your organization from legal repercussions, but also contributes to the broader efforts of maintaining global security and stability by preventing illicit financial activities. During this panel, we will explore:

• Addressing rapidly changing geopolitical events and risk factors
• Utilizing enhanced screening tools, including IP blocking and geofencing
• Improving sanctions screening protocols for better compliance
• Ensuring data accuracy and minimizing false positives
• Documenting risk assessments related to compliance with sanctions

Guidance on the SEC’s New Cybersecurity Disclosure Rule:

Best Practices for Compliance with Disclosures Related to Cybersecurity Risk Management, Strategy, and Governance for Insurance and Reinsurance Companies

On July 26, the SEC adopted amendments intended to enhance and standardize disclosures related to cybersecurity. The amendments require companies timely to disclose material cybersecurity incidents and annual disclosures related to cybersecurity risk management, strategy, and governance in a timely manner.

During this panel, we will discuss the new SEC regulations and the requirements for public companies to provide investors with information about cybersecurity risk management programs. During this panel, we will discuss:

• Countering illicit finance associated with cyber-enabled crime
• Communicating essential information about your cyber risk management program and cybersecurity performance with stakeholders
• Determining the materiality of a cybersecurity incident
• Enhancing cybersecurity capabilities as you plan for new disclosure requirements and timely disclosure of material incidents
• Strengthening your overall cybersecurity posture
• Enhancing processes and procedures to meet disclosure requirements

Networking Break

Small Group Networking Discussion by Sector

AML Compliance Hot Topics:
A – Life Insurance Sector
B – Maritime Insurance Sector
C – Property & Casualty Insurance Sector

Roundtable A

Angela Bates
AML and Sanctions Senior Compliance Officer
Corebridge Financial

Kelly Pirrotta
Head of AML, Economic Sanctions and Senior Financial Exploitation
MassMutual

Roundtable B

John Keough
Partner
Clyde and Co

Roundtable C

Mark O. Huard, FCLS, CIFI
Special Agent, Northeast Region
National Insurance Crime Bureau

Kaneez F. Madraswalla
Vice President, Compliance
QBE North America

Roundtable A – Life Insurance
Roundtable B – Maritime Insurance
Roundtable C – Property & Casualty Insurance

Our sector-specific roundtables are a platform for industry professionals to engage in focused discussions involving current regulatory and compliance challenges. These roundtables foster collaboration and knowledge-sharing, allowing participants to gain insights into emerging trends and best practices through collaborative round-table discussion.

Closing Remarks from the Co-Chairs and Day 1 Adjourns

Networking Breakfast and Registration

Opening Remarks from the Co-Chairs

Sandra Calmes
Vice President, Senior Corporate Counsel & Global Financial Crimes Officer
Liberty Mutual Insurance

Luis Duarte de Jesus
Head of U.S. Anti-Financial Crimes, OFAC and Sanctions Compliance Lead
Generali

International Perspectives:

Navigating Evolving International Sanctions and AML Complexities for the Insurance Industry

Inna Tsimerman
Chief International Trade Counsel
Arthur J. Gallagher
(WSN Member)

A comprehensive examination of the US, EU, and UK sanctions structures and AML guidelines reveals an intricate interplay between legal frameworks, policy objectives, and enforcement challenges.

During this panel, we will explore the intricate nature of the global sanctions and AML frameworks, including:

• An overview of policy objectives and the diversity of sanctions structures
• The effectiveness of sanctions based on enforcement mechanisms
• The interplay between diplomatic engagement and punitive measures
• How federal, provincial, and territorial governments are working on transparency and updates to key milestones of collaboration

Navigating the Revised AMLA:

Best Practices for Ensuring Compliance with the New Due Diligence Duties Related to Anti-Money Laundering Act Revisions

In light of the evolving landscape of financial crime and the need for more effective measures to combat money laundering and terrorism financing, the Anti-Money Laundering Act (AMLA) has recently undergone significant updates.

These updates represent a concerted effort to modernize AML practices, improve detection capabilities, and reinforce collaboration among stakeholders for a more robust financial system. During this panel, we will discuss key highlights of the AMLA updates including:

• Stricter regulations, expanded due diligence requirements, and refined risk assessment methodologies for a comprehensive approach to financial crime
• Establishing a renewed focus on identifying and verifying beneficial ownership information, increasing transparency, and fighting illicit actors who hide behind complex ownership structures
• Leveraging cutting-edge technologies, including Big Data, to increase the efficiency of transaction monitoring and suspicious activity detection

Networking Break

Developing a Risk-Based Approach to AML & Sanctions:

Programs for Insurers and Practical Tips for Effective Risk-Assessment Strategies

Jesse Aedo
Group Head of Compliance
Aspen Insurance Group

Michael Heffernan
Director, Global Financial Crimes
Liberty Mutual Insurance

Developing a risk-based approach to AML & sanctions programs is essential for insurers and reinsurers in today’s complex regulatory landscape. Companies must be vigilant in identifying and mitigating money laundering and sanctions risks while efficiently allocating resources. Effective risk-assessment strategies are critical to achieving compliance and protecting the integrity of the insurance industry. During this panel, we will discuss key considerations:

• Implementing a robust Customer Due Diligence (CDD) process
• Utilizing advances data analytics tools to monitor transactions
• Fostering a culture of compliance within the organization
• Encouraging a proactive approach to risk identification and reporting

Complying with the Corporate Transparency Act:

Navigating the CTA and Complying with FinCEN’s Beneficial Owner Reporting Rules

Charles Smith
Vice President, Global Head of Anti-Financial Crime Compliance
MetLife

The CTA, a component of the Anti-Money Laundering Act of 2020 implemented by FinCEN, was enacted to prevent money laundering, terrorist financing, and other illicit activities. It takes effect January 1, 2024. By increasing the information reported on business entities, the CTA aims to prevent the exploitation of U.S. corporations and LLCs for criminal gain and assist law enforcement in detecting criminal activity. The CTA requires companies, beneficial owners, and business applicants to file information with the U.S. Department of the Treasury. During this panel, we will explore:

• Understanding the compliance requirements related to the CTA
• Understanding the potential penalties for failing to report
• Breaking down the Beneficial Ownership Reporting rules under the CTA

Closing Remarks and Conference Adjourns