Do you have burning questions related to BSA/AML compliance? Struggling with Beneficial Owners, Currency Transaction Reports, suspicious activity monitoring, etc.?
If so, we’d love to have you join us on July 14, 2020, for our FREE BSA/AML Compliance Q & A Forum where we’ll answer questions such as:
Question: It seems we’re always getting push-back on asking for too much due diligence information upfront, how can we justify it or know that what we’re asking is in line with other banks?
Answer: Start with the sample questions given in the FFIEC’s BSA/AML Examination Manual. There’s a reason those are provided and we don’t think they can just be ignored. You’re required to obtain enough information to have what you feel is a reasonable understanding of what the customer will be doing. So, that’s the perspective you need to take. It’s much easier to get such information at account opening than it is when something pops up during the life of the account. While that may still be necessary, getting it upfront gives you a baseline, if the account activity doesn’t match up with what was expected.
Question: How frequently should our Risk Assessment be reviewed if there have been no changes?
Answer: The risk assessment provides a comprehensive analysis of your BSA/AML risks in a concise and organized manner and enables management and the Board to identify and mitigate gaps in the bank’s controls. We believe the risk assessment should be reviewed and communicated with the Board on at least an annual basis.
Have other questions? All you have to do is register for the Forum on our website and then start pre-submitting your BSA/AML compliance questions to firstname.lastname@example.org (please put “July Forum” in the subject line). We will answer as many of your questions as we can during the allotted hour.