FREE BSA/AML Compliance Q & A
Do you have burning questions related to BSA/AML compliance? Struggling with Beneficial Owners, Currency Transaction Reports, suspicious activity monitoring, etc.?
If so, we’d love to have you join us on July 14, 2020, for our FREE BSA/AML Compliance Q & A Forum where we’ll answer questions such as:
Question: It seems we’re always getting push-back on asking for too much due diligence information upfront, how can we justify it or know that what we’re asking is in line with other banks?
Answer: Start with the sample questions given in the FFIEC’s BSA/AML Examination Manual. There’s a reason those are provided and we don’t think they can just be ignored. You’re required to obtain enough information to have what you feel is a reasonable understanding of what the customer will be doing. So, that’s the perspective you need to take. It’s much easier to get such information at account opening than it is when something pops up during the life of the account. While that may still be necessary, getting it upfront gives you a baseline, if the account activity doesn’t match up with what was expected.
Question: How frequently should our Risk Assessment be reviewed if there have been no changes?
Answer: The risk assessment provides a comprehensive analysis of your BSA/AML risks in a concise and organized manner and enables management and the Board to identify and mitigate gaps in the bank’s controls. We believe the risk assessment should be reviewed and communicated with the Board on at least an annual basis.
Have other questions? All you have to do is register for the Forum on our website and then start pre-submitting your BSA/AML compliance questions to training@bankerscompliance.com (please put “July Forum” in the subject line). We will answer as many of your questions as we can during the allotted hour.
Published
06/25/2020
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!