Keeping the Board of Directors and Management informed about upcoming changes regarding BSA/AML/CFT, whether administrative or regulatory rulemakings, is crucial for the success and compliance of any institution. Regular communication about things coming down the pipeline ensures everyone is prepared and on the same page.
The proposed regulatory updates from the 2020 AML Reform Act represent emerging risks and likely adjustments to your BSA program. It’s essential to be proactive and communicate effectively. One of the key responsibilities of a BSA Officer is to monitor regulatory changes, identify and evaluate associated risks, and perform a thorough risk assessment. It’s equally important to develop mitigation strategies and ensure they are aligned with the risk appetite defined by the Board and Management.
It is also critical to document your findings and actions thoroughly. Documentation is more than a best practice – it’s a responsibility. By keeping clear records, you ensure that the Board is fully informed about regulatory changes, their potential impact and steps being taken to address them.
Kevin discussed this at our inaugural AML/CFT Membership Group meeting.