BSA / AML Review

The Bank Secrecy Act (BSA) / Anti-Money Laundering (AML) review will be an independent review of the bank’s BSA / AML program, including requirements for the Office of Foreign Assets Control (OFAC). The review will encompass the bank’s BSA / AML / OFAC risk assessment, policies, procedures, and processes and include the following:

  • Remote Deposit Capture
  • Currency Transaction Reporting (CTR)
  • Currency Transaction Reporting Exemptions
  • Monetary Instrument Sales Recordkeeping
  • Funds Transfers Recordkeeping
  • Training Initiatives
  • Customer Identification Program (CIP)
  • Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
  • Preparedness for and/or compliance with Beneficial Ownership/CDD Requirements
  • USA PATRIOT Act sections 314(a) and 314(b)
  • Suspicious Activity Monitoring and Reporting
  • Office of Foreign Assets Control
  • Other BSA Recordkeeping Requirements
  • Cash Shipments
  • FFIEC expanded procedures, if required, based on the Bank’s operations
  • Verification of the Bank’s policies, procedures, and processes to adhere to the BSA’s record retention requirements
  • Review of Regulatory Examination Results

We have extensive experience in assisting banks with BSA / AML / OFAC issues and teach hundreds of bankers each year. We also have extensive experience with banks that are subject to regulatory actions, as well as banks that simply need annual training and review functions performed for them.