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.