Would these issues crop up with your BSA examination?

One of the sessions during the 12thAnnual Mid-Atlantic Anti-Money Laundering (AML) Conference that I recently attended was on current compliance topics.  Panelists from the FDIC, OCC, FINRA, FinCEN and the Federal Reserve Board discussed some of the issues they had noted during financial institution examinations for Bank Secrecy Act (BSA)/anti-money laundering (AML) compliance.  Under the current landscape, as institutions merge, they obviously grow but also get more complex. An institution’s risks therefore increase and make internal controls even more important.  This increases the importance of independent testing performed by a qualified entity.

The panelists indicated some financial institutions had been cited for lax review procedures.  These included:

  • Insufficient reviews of accounts;
  • Conclusions inadequately supported;


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