Guarding Against the ‘Enemy Within’ – Best Practices in Employee Due Diligence at Onboarding

Financial institutions spend great time and money “onboarding” new customers to see if they pose an intolerable financial crime risk. But, financial institution employees, who spend their entire working days learning valuable information, seeing sensitive things and having access to key functions that could be compromised, sold or stolen are often scrutinized a little before they are hired and virtually forgotten after they are given the keys. The challenge is to keep good employees in and bad ones out. Recent cases, such as the TD Bank-Coquina case, show the harm employees can do to a financial institution. How should institutions and other businesses manage employee due diligence programs to reduce the risk of harm from the “enemy within”? What are the best practices for monitoring employees after they are hired? What internal controls are permissible and good for detecting and controlling illicit employee behavior? Here, our expert gives you answers, guide you on good employee due diligence procedures and shows you legal pitfalls you should avoid.

John F. Walsh, CEO, SightSpan Inc., Charlotte
A highly regarded industry leader on the subjects of risk management, financial crime risk management, security, anti-money laundering and combating terrorist financing, John has been the CEO of SightSpan Inc, since 2007. He has also held numerous high-level positions within the financial services industry, including leadership roles at Wachovia Bank, Bank of America and Merrill Lynch. His expertise and insight into international business management, compliance, security and overall operational risk management have earned him the reputation as a leader in the financial crime field.

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