BSA/AML Compliance Program
Crane Intelligence is experienced in all areas of the Bank Secrecy Act and Anti-Money Laundering Compliance Program. As an independent testing (auditing) companye are qualified and able to assess the adequacy of your bank’s BSA/AML compliance program and determine whether the bank has developed, administered, and maintained an effective program for compliance with the BSA and all of its implementing regulations.
We will do a review of the bank’s written policies, procedures, and processes as a first step in determining the overall adequacy of the BSA/AML compliance program. The completion of applicable core and, if warranted, expanded examination procedures may be necessary to support the overall conclusions regarding the adequacy of the BSA/AML compliance program. Examination findings will be discussed with the bank’s management, and significant findings will be included in the report of examination or supervisory correspondence.
Our independent testing will, at a minimum, include:
- An evaluation of the overall adequacy and effectiveness of the BSA/AML compliance program, including policies, procedures, and processes. Typically, this evaluation will include an explicit statement about the BSA/AML compliance program’s overall adequacy and effectiveness and compliance with applicable regulatory requirements. At the very least, the audit should contain sufficient information for the reviewer (e.g., an examiner, review auditor, or BSA officer) to reach a conclusion about the overall quality of the BSA/AML compliance program.
- A review of the bank’s risk assessment for reasonableness given the bank’s risk profile (products, services, customers, entities, and geographic locations).
- Appropriate risk-based transaction testing to verify the bank’s adherence to the BSA recordkeeping and reporting requirements (e.g., CIP, SARs, CTRs and CTR exemptions, and information sharing requests).
- An evaluation of management’s efforts to resolve violations and deficiencies noted in previous audits and regulatory examinations, including progress in addressing outstanding supervisory actions, if applicable.
- A review of staff training for adequacy, accuracy, and completeness.
- A review of the effectiveness of the suspicious activity monitoring systems (manual, automated, or a combination) used for BSA/AML compliance. Related reports may include, but are not limited to:
- Suspicious activity monitoring reports.
- Large currency aggregation reports.
- Monetary instrument records.
- Funds transfer records.
- Nonsufficient funds (NSF) reports.
- Large balance fluctuation reports.
- Account relationship reports.
- An assessment of the overall process for identifying and reporting suspicious activity, including a review of filed or prepared SARs to determine their accuracy, timeliness, completeness, and effectiveness of the bank’s policy.
- An assessment of the integrity and accuracy of MIS used in the BSA/AML compliance program. MIS includes reports used to identify large currency transactions, aggregate daily currency transactions, funds transfer transactions, monetary instrument sales transactions, and analytical and trend reports.
Our auditors will document the audit scope, procedures performed, transaction testing completed, and findings of the review. All audit documentation and workpapers will be available for examiner review. Any violations, policy or procedures exceptions, or other deficiencies noted during the audit will be included in an audit report and reported to the board of directors or a designated committee in a timely manner. The board or designated committee and the audit staff should track audit deficiencies and document corrective actions.