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.
Published
2024/05/21