Bank Secrecy Act and Financial Recordkeeping Regulations
The recent release of the BSA/AML examination guidelines demonstrates continued regulatory emphasis on BSA/AML compliance. DD&F provides solutions to ensure that a proper compliance program exists including employee training and program testing or auditing. DD&F also ensures that the procedures to be preformed meet all of the testing requirements contained in the FFIEC Manual.
DD&F will evaluate the Bank's compliance with the Bank Secrecy Act and Financial Recordkeeping Regulations. The assessment will include the following:
- An evaluation of the overall integrity and effectiveness of the BSA/AML compliance program, including policies, procedures, and processes.
- A review of the bank's risk assessment for reasonableness given the bank's risk profile (products, services, customers, and geographic locations).
- Appropriate risk-based transaction testing to verify the bank's adherence to the BSA recordkeeping and reporting requirements (e.g. CIP, SARs, CTRs, and CTR exemptions, and information sharing requests).
- An evaluation of management's efforts to resolve violations and deficiencies noted in previous audits and regulatory examinations, including progress in addressing outstanding supervisory actions, if applicable.
- A review of staff training for adequacy, accuracy, and completeness.
- A review of the effectiveness of the suspicious activity monitoring systems (manual, automated, or a combinations) used for BSA/AML compliance.
- An assessment of the overall process for identifying and reporting suspicious activity, including a review of filed or prepared SARs to determine their accuracy, timeliness, completeness, and effectiveness of the bank's policy.