BSA Risk Assessment and Plan

 

The costs of failing to comply with BSA/AML regulations can potentially devastate a financial institution.  In response, many financial institutions have significantly increased staff in this area and invested heavily in technology systems to support the compliance effort.  As a result, the day-to-day costs of compliance are almost as equally devastating.

With regulatory emphasis on BSA/AML expected to increase as the credit crisis wanes, now is the time for financial institutions to ensure their compliance efforts meet regulatory requirements.

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Cadre will work with your institution to ensure that you have

• Developed appropriate product, service, location, customer and other risk assessments required by regulation

• Documented board-approved BSA / AML policies appropriate to the Bank’s risk environment.

• Implemented a system of internal controls, commensurate with the institution’s risk profile

• Designated individuals responsible for coordinating and monitoring day-to-day compliance and staffed accordingly

• Provided training for appropriate personnel

• Provided appropriate independent audit by in-house personnel or an independent outside party

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Most importantly, Cadre will help ensure that the BSA/AML compliance function is both effective, and cost effective.

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Other BSA/AML Risk Services

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Cadre can also assist your financial institution in the following areas to improve the effectiveness and efficiency of your BSA/AML compliance effort:

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• Developing a comprehensive risk-based BSA/AML/CIP/OFAC program that includes a customized institution-wide risk assessment

• Developing a program to risk-assess your customer database

• Performance of Enhanced Due Diligence (“EDD”) on High-Risk Customers

• Performance of BSA/AML review services for your institution’s Money Service Business (“MSB”) customers.

• Transaction Lookbacks and Forensic Auditing - Cadre prepares a retroactive review of your institution’s customer transactional accounts for suspected illegal or unusual activity. We coordinate the investigation process on all transactions that exceed the developed thresholds through the use of our proprietary Case Management System (“CMS”).

• BSA/AML Software Validation - We additionally provide validation of the transactional data and parameters utilized within your institution’s BSA/AML software through a review of underlying transactions.

• Best Practice Reviews of BSA/AML Compliance staffing, organization, workflows and systems

• Compliance GAP analyses and testing.

• Comprehensive BSA/AML Audits.

• Training for Directors, Management and staff.

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The regulatory message is clear.  All financial institutions are expected to have a clearly defined and well-implemented BSA program in place.  However, financial institutions must make wise investments in people and systems to assure this compliance.

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