Do you have burning questions related to BSA/AML compliance? Struggling with Beneficial Owners, Risk Assessments, Currency Transaction Reports, High-Risk Customers, etc.? If so, we’d like to invite you to join us on July 19, 2022, for our FREE BSA/AML Compliance Q & A Forum, where we’ll answer questions such as:
Question: We are a smaller bank, and our BSA, Compliance, and Audit function are all managed by the same person. Can our audit department do an “independent” audit of the program?
Answer: This is tough for small institutions because you likely just don’t have multiple people that are even qualified to conduct a BSA audit, let alone an independent one. I would say if the person doing the audit is under the same reporting line as the others, for instance the BSA officer, it could be criticized. The person conducting the audit must be truly independent from the BSA AML function.
Question: I am new to my bank and I think I have a good understanding of the Customer Due Diligence (CDD) requirements, but I’m just not sure how will I know if or when there should be Enhanced Customer Due Diligence (ECDD)?
Answer: In many cases, your BSA personnel has likely already determined which customers or categories of customers they feel should be subject to ECDD procedures based on their risk. For example, certain cash-intensive business, those with a privately-owned ATM, marijuana-related businesses, etc., and they will carry that enhanced monitoring. However, you still play a crucial role in looking for suspicious activity that might lead to the need for ECDD. If you notice something suspicious or something that just doesn’t seem right, report it to your BSA personnel so they can take a closer look and determine if ECDD is warranted.
All you have to do is register for the Forum on our website and then start pre-submitting your deposit 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.
See you there!!
Published
2022/06/16
