Auditing Your BSA/AML Program

Auditing your BSA/AML program encompasses a lot of different requirements. From currency transaction reporting and suspicious activity reporting to beneficial owners and customer due diligence, there is a lot an auditor needs to be aware of. One thing you don’t want to glaze over during an audit are those requirements that have been in place for quite a while that you think are running just as intended, like a well-oiled machine. Once such area is your Customer Identification Program (CIP). It’s not uncommon for us to go into institutions where over the years there have been changes to products and services or the day-to-day procedures but those ultimately were never incorporated into the written CIP. What the policy says isn’t what is actually happening, and this could be a red flag to examiners concerning the management of your overall BSA/AML program.

Kevin explains more in the video.

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Kevin Edwards

Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).

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Auditing Your BSA/AML Program