Under the Bank Secrecy Act FinCEN (Financial Crime Enforcement Network) is issuing final rules to strengthen customer due diligence requirements for banks, mutual funds, etc. Essentially, banks will be required to know the identity of individuals who own or control their legal entity customers. To accomplish this there will be four core elements to following these due diligence rules. (1) Banks must identify and verify the identity of their customers. (2) Beneficial owners of legal entities must be identified and verified; additionally, they must also identify and verify other individuals who have the authority or ability to manage or control an entity. (3) The bank must understand the customer relationship for the purpose of developing a risk profile for that customer. And (4) finally they must develop a system to monitor the customer on an ongoing basis for the purpose of detecting suspicious activity and/or updating customer information. The rules dictate that these measures must be in place by May 2018.
It is because of such rules that all banks and financial institutions, along with companies like IATS that routinely work with them, will become more consistent and uniform in their administration of BSA and due diligence efforts, and in so doing, will follow a broad strategy of enhancing transparency of legal entities.
Kirk Woford and Joan Roberts recently attended the European Business Aviation Convention & Exhibition (EBACE) Conference, which took place May 22-24 in Geneva, Switzerland. Accompanied by Chairman Charles McGettigan, the IATS group was joined by business leaders, government officials, manufacturers, flight department personnel, avionics firms, fractional providers, charter/lease companies and all manner of people involved in nearly every aspect of business aviation around the world.
Hopefully, we saw you there, but if we didn’t, look for us at the upcoming Helicopter Association International (HAI) Heli-Expo early next year or at the NBAA (National Business Aviation Administration) conference next October in Las Vegas.
If you’re a client visiting Oklahoma City this month, you picked the perfect time! Not only is OKC beautiful during the spring, it is also jam-packed with fun events and goings on for natives and visitors of all ages!
Now through May 28, Disney’s “The Lion King” returns to OKC! More than 85 million people around the world have experienced the awe-inspiring visual artistry, the unforgettable music, and the uniquely theatrical storytelling of this Broadway spectacular. Many believe it is one of the most breathtaking and beloved productions ever to grace the stage, and we are thrilled to have it in Oklahoma City! Buy your tickets here.
The inaugural Oklahoma City Whitewater Festival will take place May 18-21 at RIVERSPORT Rapids near Bricktown on the Oklahoma River and will host many whitewater rafting and kayaking events. This four-day whitewater celebration will include the R4 Rafting National Championship and USA Canoe/Kayak Canoe Slalom trials, plus downriver and freestyle kayaking competition. USA Canoe/Kayak Whitewater Canoe Slalom trials will determine which athletes represent the U.S. for the 2017 World Cup season and will take place May 18-20. To learn more about this event or all that RIVERSPORT OKC has to offer, visit their website.
More than 80 visual artists will fill the historic Paseo Arts District for the 2017 Paseo Arts Festival May 27-29, selling original artwork in a wide variety of media, from painting and photography to wood and jewelry. The festival also hosts dozens of live performers and musicians. The food court at Paseo Drive and 29th Street will feature a variety of food vendors, bringing traditional and not-so-traditional festival treats, both savory and sweet. To learn more about the galleries located at the Paseo or the district’s history, visit their website.
Stay tuned for more information about events in and around the city! We love OKC and hope all visitors will feel the same way after their visit!
Given the heightened level of transparency necessary for those of us in financial services who must deal with banks and customers alike, Insured Aircraft remains steadfast in its commitment to compliance and knowing its clients. We take those extra steps to identify our customers and to know not only the sources of funds but also to verify the recipients of disbursements. We recognize the paramount importance of monitoring financial activities in a world where businesses must be concerned with avoiding money laundering, terrorist financing, or other financial related crimes.
In order to stay up-to-date on the latest developments and technologies on these topics, some of our team members routinely attended the annual BSA/AML Top Gun Conference. Our own Bridget Sanford and Amy Chabiel attended the conference this past March in Scottsdale, Arizona, and they came home with new ideas and a deeper understanding of, not to mention a renewed commitment to, the challenges our industry faces. Topics that they and their banking colleagues attended included such items as “Creating a Culture of Compliance,” “Due Diligence and Customer Risk Profiles,” “Building an Enterprise-wide BSA Quality Control Program,” and “BSA Cyber Edition”.
Every member of our team is thoroughly committed to compliance because not only does it protect us from potential threats, it also helps us protect our customers, our top priority.
IATS is proud of many things, but one of the most important of these is our wholehearted support for our troops. We are honored to say that one of our Escrow Agents, Josh Tremain, is currently serving our country abroad as a soldier in the Air National Guard.
Josh was deployed last fall shortly after the birth of his son, Isaac, and we are thrilled that his tour will be ending soon and will be rejoining our team back home this summer. We know his wife, Tracey, and baby “Ike” are counting the days until he’s home, safe and sound.
On behalf of each and every member of the IATS team, thank you, Josh, Tracey, Ike, and all of our brave servicemembers and their families for sacrificing so much to defend our country. Know that we wholeheartedly support you, and pray for your safe return home.
As you may already be aware, IATS takes compliance issues and due diligence very seriously. We make it our duty to stay informed about the latest updates in regulation and compliance mandates for financial transactions. A major part of this initiative is our attendance at the Bankers Online BSA/AML Top Gun Conference each year.
This year’s conference will take place March 29-30 in Scottsdale, AZ, and we view this event as an opportunity to listen to and interact with nationally recognized presenters from BankersOnline.com. It also allows us a unique opportunity to get some rare “how to” instruction in BSA/AML compliance issues.
Topics such as creating a culture of compliance, due diligence, customer risk profiling, and beneficial ownership are on the agenda, and we’re eager to gain insight into how we can improve and strengthen our responsibilities in these areas of our work.
In our digital age, identity thieves are constantly finding new ways to attain people’s personal information. Companies within the financial industry, for example, are under attack each day and work tirelessly to combat the risks posed to them. Something you can do to protect yourself is to pay particular attention to email attachments you receive.
The latest in phishing scams pertains to using fake DocuSign and Secure Adobe PDF attachments in an attempt to trick employees into opening them, at which point a malicious link would open in the browser.
Spoofing emails are also becoming increasingly formidable. All one needs to spoof an email address is an SMTP (Simple Mail Transfer Protocol) server (a server that can send email) and the appropriate email software. Showing a different “from” address than the actual registered domain is easy to do with many of the free SMTP servers, and this address may look very similar to the one they’re attempting to impersonate.
So how can you protect yourself? 1) Use your spam filters. Nearly every email service has spam filters and junk boxes. 2) Investigate the email. Even if it looks like it’s coming from someone you know, email spoofers are skilled at claiming nearly identical addresses. 3) Never click an unexpected link or download an unfamiliar attachment. Generic emails saying “Your account has been compromised, click here to validate” are red flags. Legitimate banks and institutions will identify you by name and ask you to call them if they have reason to believe your account has been intruded. Above all, do research, stay vigilant, and trust your instincts. Check and re-check email addresses, and never click on anything that seems odd in any way.
Check back soon for more tips about staying cyber secure.
The movement of money from one party to another is what makes the financial world go ‘round, and there are multiple avenues in which this takes place. The two primary modes of monetary transportation are ACH payments and wire transfers. Both get the money to their destination, but requirements and time differentiate the two. So, which is better?
Current trends tend to favor ACH payments because they are automated and convenient when it comes to making these types of payments. Most of us are very accustomed to the use of ACH payments, which range from making household payments to receiving our paycheck via direct deposit. They are often represented as practical and sound alternatives versus wire transfers and are desirable for repetitive payments, high volumes of payments, or directly managed payments. Accordingly, they tend to be less expensive because they can be handled directly by the sender, sending their funds through an automated clearing house (ACH) that clears the payment and directs it onto the recipient. Therefore, direct intervention on the part of the bank in the transaction process other than setup or corrective issues is rare.
Wire transfers, on the other hand, move money directly between financial institutions in real-time, allowing them to be completed the same business day and providing for a very secure payment process. Despite this efficiency, wire transfers can be more costly due to greater security in a controlled environment.
So we ask the question again… which is the better choice? For escrow purposes, we believe the answer is wire transfer. A wire represents an almost immediate transfer and once credited, the funds are immediately available for use. The banks have controls in place to ensure that final settlement (i.e. the payment is irrevocable) occurs upon the credit of the funds. Unlike ACH transactions, there are no allowances to be made for the possibility of an error or a correction/recall of the funds. For an ACH transaction, depending on the situation and/or the type of ACH, the recall period may be as few as three days or as long as 59 days.
For many people and companies, ACH payments are the way to go because of convenience, cost, and timing; but if the transaction involves large sums of money and there must be no conditions or delays involving the use of those funds, then a wire transfer is a more effective solution.
In any case, we always recommend researching the ins and outs of financial payments and transfers, especially if you’re in the midst of a transaction that is particularly important or involves the transfer of a large sum of money.
Happy New Year from IATS! As a continuation of our campaign to promote the greatness of Oklahoma City, we invite you to make a trip to the Oklahoma City Museum of Art (OKCMOA) on your next visit. The Museum’s 110,000 square foot facility, constructed in 2002, is located in the heart of downtown and is an anchor for a growing cultural district of the greater metropolitan area.
Accredited by the American Association of Museums, OKC serves over 125,000 visitors annually from all fifty states and over thirty foreign countries. The Museum’s collection covers a period of five centuries with highlights in European and American art from the nineteenth through twenty-first centuries, a growing collection of contemporary art, and one of the world’s largest collections of glass sculpture by Dale Chihuly.
The Museum also boasts the region’s premier repertory cinema, which screens the finest international, independent, and classic films, and is home to the Museum School, which offers classes for students of all ages as well as art camps for children. Enjoy all that fine art has to offer at the Oklahoma City Museum of Art!
They say the neon lights are bright on Broadway, but they’re just as bright in Oklahoma City! Put a little song and dance into your next visit to Oklahoma City by attending one of the 2016-2017 Broadway Series concerts and theatrical performances.
Classics such as “Pippin,” “The Lion King,” and “Newsies” join together new shows such as “Elf” (holiday season) and “Motown: The Musical” at OKC’s beautiful Civic Center Music Hall. This is a can’t-miss lineup for lovers of the arts visiting Oklahoma City. View the schedule and buy tickets online here.
We couldn’t be prouder of the place we call home: Oklahoma City. Therefore, in honor of the holiday season, we would like to tell you a little bit about the goings-on and must-see sites in our great city in case you happen to find yourself in town over the course of the next month.
The National Cowboy and Western Heritage Museum, founded in 1955, collects, preserves, and exhibits an internationally renowned collection of Western art and artifacts while sponsoring dynamic educational programs to stimulate interest in the enduring legacy of the American West – a history that permeates our national culture.
From bronze sculptures to large-scale landscape paintings and Native American artifacts, the Museum tells a visual story of the American West from many different perspectives. Learn more about the museum including hours and admission information here.
IATS invites you to embark on a western adventure next time you’re in town!
Kaelyn Thompson, the daughter of IATS Escrow Agent Kim Thompson, was born with Cystic Fibrosis and underwent her first double lung transplant at Duke University in September 2013. Unfortunately, her health started to decline and has recently undergone her second double lung transplant.
Kaelyn and members of her immediate family are once again living in North Carolina away from her brother, family, and friends, and need all the prayers, love, and support you can send their way. Donations are greatly appreciated, all of which go towards paying medical expenses for the lung transplant, prescriptions, and the relocation to North Carolina. From Kaelyn and all her family, we want to thank everyone in advance for your support at this time of need and, most importantly, urge you to save a life by becoming an organ donor.
Earlier this year, the Financial Crimes Enforcement Network (FinCEN) issued a final rule that creates a fifth “pillar” for anti-money laundering (AML) programs required under FinCEN’s rules for banks. Since the passage of the USA Patriot Act, the four pillars of an AML program—internal controls; independent testing; designation of an individual responsible for day-to-day compliance; and training—have been amended to include a fifth pillar mandating that AML programs establish risk-based procedures for conducting ongoing customer due diligence (CDD). This includes the development of customer risk profiles and implementation of ongoing monitoring to identify and report suspicious activity and, on a risk basis, to update customer information. The amendments further specify that CDD includes, in addition to obtaining beneficial ownership information: (1) understanding the nature and purpose of customer relationships for the purpose of developing a customer profile, and (2) ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to update customer information—including beneficial ownership.
Similarly, FinCEN announced that it had issued a Geographic Targeting Order (GTO) that would temporarily require certain title insurance companies to report the identity of natural persons who make “all cash” purchases of high value residential real estate through shell companies in New York County (Manhattan) and Miami-Dade County. This latest risk-based approach by FinCEN to combat money laundering is designed to reduce the ability of individuals to hide the proceeds of criminal activity through anonymous real estate purchases. Title companies that fail to collect and report this information to FinCEN may be subject to penalties or other action.
Accordingly, as a proactive company with its own financial institutions, IATS recognizes that the banking industry’s reach must also extend to institutions that process transactions through banks. We understand this role and assert we will continue to make the necessary steps to identify and monitor our clients through our own due diligence program. We will continue to request and screen information from all clients to whom or from whom funds flow, the core element of which will most certainly rest with beneficial ownership of a commercial entity for the same reasons discussed above. Rest assured that throughout this process, IATS continues to recognize our fiduciary responsibility to maintain the privacy and confidentiality of records we request.
The NBAA-BACE Conference is coming to Orlando November 1-3, 2016, and IATS is excited to attend! Our President, Kirk Woford, and Vice President/Escrow Agent, Joan Roberts, will be our “boots on the ground” at the conference, and they’re looking forward to seeing old and new clients alike. As always, the conference features exhibits, professional development programs, education sessions, and, of course, opportunities for networking! Say “hello” to Kirk and Joan if you see them there!
The best time of year is just around the corner: Thunder season! As the 2016-2017 season opens October 26, IATS is proud to be long-time supporters of our city’s team. If you’re a client and in town for a game, a closing, or just a visit with your favorite escrow agent, make sure to attend one of the games and see why our players and fans are the best around. While you’re here, be sure to stop by IATS to try on a pair of Kevin Durant’s shoes! We have a pair on display and encourage everyone to them on for size (at size 18, don’t be surprised if they’re a little big). Thunder up with IATS!
Even though you don’t need the FAA’s permission to fly your drone (55 lbs or less), you still need to register it, and IATS has everything you need to do just that. We make the process of registering your drone easy and are here to answer any questions you have regarding regulations and requirements. Above all, safety is key, so if you have questions, ask us and we’ll be glad to research current pilot requirements, aircraft requirements, airspace regulations, and time of day and general operation rules. Have fun and fly safely!
Upon reading journalistic descriptions of the life of Mr. Matthew E. G. Kelly, Chairman and Owner of Insured Aircraft Title Service (IATS), one is presented with words such as “humor,” “engaging personality,” “charming,” and “love of life”. Mr. Kelly celebrated life, and in the words of his wife, Diane, “He had great charm, a ton of friends and really lived each day like it was his last. He certainly lived life to the fullest”. At 95 years young, he lived a long and full life in success and happiness. Most importantly, he loved what he did.
After purchasing IATS in 1985, he nurtured this company, helping it grow into one of the world’s largest aircraft title and escrow companies. In order to ensure the company’s longevity, Mr. Kelly placed the IATS shares into a trust. The Matthew E. G. Kelly Trust named Charles C. McGettigan, Chairman and CEO, as one of the co-trustees.
We have no doubt that our company has been placed in trustworthy and capable hands, and that it will only continue to grow and flourish. As a true testament of Mr. Kelly’s lasting legacy, everyone at IATS is dedicated and passionate about our work. Simply put, we love what we do, and we have Mr. Kelly to thank for that.
As part of its ongoing commitment to compliance regarding BSA (Bank Secrecy Act) and AML (Anti Money Laundering), two members of our team, Christopher Fiegel and Tiffany Foxx, joined compliance officers from banks around the country by attending in person the 9th Annual Bankers Online (BOL) BSA/AML Top Gun Conference in Scottsdale, Arizona on March 22nd and 23rd.
With representatives from banking, Federal oversight agencies, law enforcement, consulting firms, and advocacy groups, the focus of the conference was to continue to educate, update, and advise bankers with respect to the current and changing aspects of compliance facing bankers today, many of which are directed at the bankers’ ability to monitor, identify, and report activities by its customers that may involve criminal activity by a customer or criminal activities directed at their customers. Given the ever changing landscape of compliance as it applies to suspicious activity, to training, to government sanctions, and to the multitude of abuses of financial products through banks and other financial services, it is important for IATS to also understand these pieces along with all of the formal and informal processes and risks associated with them so that it can then itself follow many of the steps necessary to protect the financial institutions, its clients and itself.
While our top priority, as with any company, is service to our clients, it was quite apparent that anyone involved in financial services in these times must dedicate themselves to, not only the processing of a transaction for their client, but also to knowing and overseeing the client transactions that are being handled. This active oversight is an ongoing piece of our partnership role with the banks as they process our transactions among the many others that pass through them. As such, IATS will continue to do its best to train and develop its staff and systems in order to monitor and evaluate transactions, evaluating both sources and uses of funds, while also knowing who represents an entity from a beneficial ownership perspective as well as from a controlling interest role.
The NBAA Business Aircraft Finance, Registration, and Legal Conference took place February 10-12 in Boca Raton, Florida.
The agenda featured highly regarded experts in aviation finance, aircraft utilization options, regulatory topics, tax planning and risk management. With business aviation having a global footprint, the conference also provided strategies for evaluating aircraft registry options and managing complex international tax issues.
IATS’s Joan Roberts, Vice President and Escrow Agent, attended the conference and interacted with a number of clients.
IATS was honored to attend the 2016 Helicopter Association International (HAI) Conference in Louisville, Kentucky. The conference was the world’s largest helicopter trade show and exposition.
The purpose of the conference is to allow thousands of operators, pilots, maintenance technicians, managers, and safety professionals worldwide to gather together to learn about the latest in aircraft and technology, connect with vendors, and network with industry peers.
Attendees were also afforded helicopter-specific educational opportunities, such as inspection authorization renewal, HAI Professional Education courses, and the “Rotor Safety Challenge,” a free safety education program.
Attendees from IATS included Kim Thompson, Megan Newberry, and Bill Morgan.