|
The Bank
Secrecy Act has continued to be an
area that is closely examined by
regulators. Regulations in the BSA
area have increased exponentially in
the past few years creating
extensive compliance burdens for
banks. BLU3 can assist financial
institutions in assessing the
adequacy of the BSA/AML compliance
program to determine whether the
bank has developed, administered and
maintained an effective program for
compliance with BSA and all of its
regulations. BLU3 can perform
Independent Internal Audits, BSA
Risk Assessments, or BSA
Procedural/Policy Review Consulting.
Full Scope BSA Audits will include:
Review the bank’s board approved
written BSA/AML compliance program
to ensure it contains the required
elements
Review the bank’s board approved
written BSA/AML/OFAC Risk Assessment
to ensure all areas of risk have
been identified and the assessment
helps the bank manage risks.
Ensure the bank employees adequate
staffing to carry out the BSA/AML/OFAC
policies and procedures. Dual
control and segregation of duties
are in effect as needed to minimize
risk.
Ensure an effective Office of
Foreign Asset Control (OFAC) program
is in place.
Verify that effective Training has
been completed for all bank
employees in reference to the BSA
program.
Ensure the bank has implemented
risk-based customer due diligence (CDD)
policies, procedures and processes.
Review the Currency Transaction
Reporting procedures and ensure that
the CTR’s are filed timely and
accurately on the appropriately
designated form. Review all
exemptions and the exemption review
processes and procedures.
Ensure that the bank has the ability
to monitor aggregate transactions
for reporting purposes and
suspicious monitoring purposes.
Verify the bank has implemented
sufficient controls and monitoring
systems for the timely detection and
reporting of suspicious activities.
Ensure that effective recordkeeping
and retention for Monetary
Instruments and Funds Transfers is
in place.
Assess the adequacy of the bank’s
policies/procedures implemented to
manage the risk associated with
Money Service Business (MSB)
accounts.
Verify that the bank has implemented
a Customer Identification Program
(CIP) to effectively verify the
identities of customers opening new
accounts.
Assess the adequacy of the bank’s
systems to manage the risks
associated with electronic banking
customers, including Remote Deposit
Capture activity and management’s
ability to implement effective
monitoring and reporting systems.
|
