All in BSA

Bank Secrecy Act rules and regulations are complex, challenging, and at times, overwhelming.  Not only must a BSA/AML professional be able to complete daily tasks like reviewing transactions and filing reports, but they also must be a knowledge expert in the many areas of the Bank Secrecy Act.  For this reason, many financial institutions employ professionals who specialize in the Bank Secrecy Act and anti-money laundering rules and regulations.

But what happens when this specialist leaves the financial institution?

Unfortunately, financial institutions sometimes find themselves in a difficult situation when a BSA professional gets promoted or leaves their organization.  This is where having continuity in BSA/AML knowledge in a financial institution is important. In fact, the FFIEC BSA Exam manual states that a BSA program should have continuity despite changes in employees.  In order to do this, cross-training of employees in BSA & AML rules is essential.

On December 3, 2018 FinCEN and the joint agencies released an advisory to encourage and support the implementation of responsible innovation and new technology in the financial system.  The advisory encourages banks and credit unions to take innovative approaches to their Bank Secrecy Act (BSA) programs for combating money laundering, terrorist financing, and other illicit financial threats.  

Conducting BSA Board Training

This Compliance Clip (video) provides a number of practical tips on how to execute a good BSA training session for your Board of Directors. Adam provides three main things that could be included in Board training and explains several best practices for ensuring an effective training session. The video concludes by discussing a valuable resource that may assist some BSA Officers in training their Board.

On November 5, 2018, the FFIEC released a joint statement to alert financial institutions to recent actions taken by the Treasury’s Office of Foreign Assets Control (OFAC).  These actions were taken under OFAC’s Cyber-Related Sanctions Program and have potential impact on financial institution’s operations, including the use of services of a sanctioned entity.

One of the most challenging parts of any financial institution’s Bank Secrecy Act (BSA) program is to have an effective Customer Identification Program (CIP) that forms a reasonable belief that the institution knows the true identity of the person they are opening account for.  Understanding CIP requirements is essential as an insufficient CIP program can lead to significant consequences such as regulator enforcement actions and civil money penalties (fines). This article discusses some of the general CIP requirements for Banks and Credit Unions.