Auditing for Compliance Part I: BSA/AML/CIP
A vital and mandatory component to a BSA compliance program involves provisions for the independent testing or auditing for compliance.
Several recent enforcement actions have cited deficiencies within the BSA/AML audits.
Particular emphasis has been placed on the inadequacies of the scope, transactional testing and subsequent follow-up on findings. Whether you are an internal auditor or an outsource vendor, this program will help you identify deviations from laws, regulations and the institution’s policies, document your procedures and report the findings to management.
- Determining the objectives and scope of the audit that will include the required components,
- Developing or adapting workpapers that adequately document the audit work performed and support the audit reports and
- Preparation of written conclusion summaries, recommending corrective action and communicating findings to management.
Risk management officers, new and experienced BSA/ compliance officers and auditors. BSA/compliance officers can also use this program as a training tool for all applicable personnel.
Patricia Cashman was formerly a partner in Cashman Compliance Solutions, LLC. She was responsible for consumer compliance reviews, BSA/AML reviews, and compliance and BSA training. Patricia began her banking career in 1969. She has been the senior operations officer for three Dallas-Ft. Worth area community banks, an assistant examiner for the Texas Department of Banking and she managed the compliance/internal audit division of TIB – The Independent BankersBank, one of the largest bankers’ banks in the country. Additionally, Patricia has presented webinars for the ABA, BOL and has taught at TBA and ABA Compliance Schools. She has also been a speaker/trainer for numerous banks and compliance organizations.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2 hours/session
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