Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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1/30/2008 Pandemic Planning: When Telecommuting Will Not Be Enough

Imagine: Avian flu breaks out in southern Asia and soon moves to Singapore and Australia. Cases appear in San Francisco and your bank has 12% absenteeism within three weeks of when U.S. infections are confirmed. Five weeks later, absenteeism approaches 40%. Healthcare facilities are overwhelmed. You had stockpiled anti-viral medications but supplies are exhausted well before the height of the pandemic. Some of your employees live in an area that has been quarantined because of high infection rates. Schools in other areas are closed and families have to choose a parent to stay home. The area in which your institution is located has two-hour blackouts during the workday. Branch offices are so understaffed that they only keep drive-in windows open. How do you minimize the damage to your institution? Who is responsible for implementing the part of your business continuity plan relating to a pandemic, a very different situation from a time and location specific disaster such as a terrorist attack? How flexible will regulatory agencies be when staff shortages make certain compliance requirements all but impossible? These are issues that were addressed in the Pandemic Flu Exercise of 2007 in September and October 2007. In a period of three weeks, government agencies and 2,700 financial institutions conducted the largest pandemic exercise ever held for the financial services industry. What examiners will be looking for from financial institutions in preparation for a pandemic has been detailed by the Federal Financial Institutions Examination Council, which issued an Interagency Statement on Pandemic Planning in December 2007. The results of the Exercise and the pandemic planning guidance will be discussed in detail in the February issue of the Monitor.

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