Today, Bank Secrecy Act compliance has never been more
complex. Regulators are constantly "raising the bar" and
requiring greater efforts to detect, prevent and report suspected money
laundering, terrorist financing and other crimes.
Financial institutions must have an up-to-date BSA/AML Compliance
Program consistent with its BSA/AML risk profile. The Program
must be fully implemented and meet current BSA regulatory
requirements. Policy statements are no longer sufficient -
practices must coincide with written policies, procedures and
processes. At minimum, BSA/AML Compliance Programs must provide
for:
-
A system of internal controls to ensure ongoing compliance.
- Independent testing of BSA/AML com[compliance.
- Designation of an individual responsible for managing BSA compliance.
- Training for appropriate personnel.
The board of directors, acting through senior management, is ultimately
responsible for ensuring an effective BSA/AML Compliance Program.
Keeping the BSA/AML Compliance Program up to date with the evolving
regulatory guidance is a constant challenge for the designated BSA
officer. Even the best programs can fall behind the curve.
We have the solution.
We know the Bank Secrecy Act, the USA Patriot Act and the 2007 FFIEC
Bank Secrecy/Anti-Money Laundering Examination Manual. We also
know what regulators are looking for and can work with BSA managers to
review and update Bank Secrecy Act Compliance Programs to meet the
compliance requirements contained in the 2007 FFIEC BSA/AML Examination
Manual. We can take these requirements and provide customized
policies, procedures, forms and training to give an up to date,
cost effective and efficient BSA/AML Compliance Program