Auditing Your Bank Secrecy Act Program
As part of the scoping and planning process, examiners should obtain and evaluate the supporting documents of the independent testing (audit) of the bank's BSA/AML compliance program.
The federal banking agencies’ reference to “audit” does not confer an expectation that the required independent testing must be performed by a specifically designated auditor, whether internal or external. However, the person performing the independent testing must not be involved in any part of the bank’s BSA/AML compliance program (for example, developing policies and procedures or conducting training).
Audit findings should be reported directly to the board of directors or a designated board committee composed primarily of or completely of outside directors. The scope and quality of the audit may provide examiners with a sense of particular risks in the bank, how these risks are being managed and controlled, and the status of compliance with the BSA. The independent testing scope and work papers can assist examiners in understanding the audit coverage and the quality and quantity of transaction testing. This knowledge assists the examiner in determining the examination scope, identifying areas requiring greater (or lesser) scrutiny, and identifying when expanded examination procedures may be necessary.
Attendees will receive a 100+ page audit worksheet.
- How to use the exam manual to complete a good audit
- Reviewing and analyzing your institution based on our audit worksheet
- What to do with audit findings
- Who should do the audit and why
- Developing a good audit process
- What you have to cover during the audit
BSA Officers, Security Officers, Investigators and BSA Staff
Deborah Crawford is the President of Gettechnical Inc., a Virginia based training company. She specializes in the deposit side of the financial institution and is an instructor on IRAs, BSA, Deposit Regulations and opening account procedures. She was formerly with Hibernia National Bank (now Capital One) and has bachelor’s and master’s degrees from Louisiana State University. She has 27 years of combined teaching and banking experience.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CE Credits
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