“Shifting our risk management concerns to the professionals at Bankers Service has reduced our costs, ensured compliance, and allowed staff to focus on customer service instead of rules and regulations.”

Mike Simpson

Bank Secrecy Act and Anti-Money-Laundering Audits

According to BSA regulations, an independent party must perform an independent test of a bank’s Bank Secrecy Act compliance program at least annually.

Procedures performed in an independent BSA Review primarily consist of the following:

  • Review and determine the adequacy of the Board approved BSA/Anti-Money Laundering Policies and Customer Information Program;
  • Sample transactions to determine the integrity and accuracy of the systems for reporting large currency transactions;
  • Review the accuracy of tellers work and the completion of Forms 104;
  • Determine the integrity and accuracy of the institution’s recordkeeping activities;
  • Sample new accounts (DDA, Savings, CD’s, Loans, Trust) for CIP requirements;
  • Sample wire transfers to determine the accuracy of forms and collection of required information;
  • Review the accuracy and reasonableness of exempted customers;
  • Determine the appropriateness of monitoring procedures for suspicious activity;
  • Sample ‘high risk’ customers to determine possible suspicious activity;
  • Review the appropriateness of recordkeeping procedures for the sales of monetary instruments in cash between $3,000 and $10,000;
  • Determine if procedures are in place to provide for compliance with OFAC requirements and 314(a) requirements;
  • Review the adequacy of the institution’s ongoing training program;
  • Review the Bank’s internal risk assessment of compliance with BSA requirements and analysis of high risk customers.

Each review’s procedures and findings are submitted to the Board of Directors in a written report.

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