BSA Officer

A Bank Secrecy Act (BSA) Officer works within a bank, credit union, or similar financial institution to ensure compliance with laws and regulations pertaining to the Bank Secrecy Act.  The act requires financial institutions to help fight money laundering.  The BSA Officer’s role is essential to a financial institution’s laws, regulations, and bank policies. Typical […]

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BSA Compliance Program

The USA Patriot Act Section 352 states the BSA (Bank Secrecy Act) Compliance Program which requires financial institutions to establish anti-money laundering programs (AML), which at a minimum must include: the development of internal policies, procedures and controls; designation of a compliance officer; an ongoing employee training program; and an independent audit function to test […]

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AML Transaction Monitoring

Anti-money laundering (AML) transaction monitoring is a software for banks or other financial institutions (FI). This software allows FIs to monitor their customers transactions on a daily basis in order to monitor risk. Using the information generated from the software, along with the customers’ historical information and account profile, the FI is able to create […]

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Customer Due Diligence / CDD

Customer Due Diligence (FinCEN CDD Rule) became effective on May 11, 2018. It has four core requirements.  It requires covered financial institutions to establish and maintain written policies and procedures that are reasonably designed to (1) on a risk basis, maintain and update customer information; (2) identify and verify the identity of customers and identify […]

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Enhanced Due Diligence / EDD

As noted in the Federal Financial Institutions Examination Council (“FFIEC”) Bank Secrecy Act / Anti-Money Laundering Examination Manual, customers that pose higher money laundering or terrorist financing risks present increased exposure to banks; therefore, due diligence policies, procedures, and processes should be enhanced as a result. Enhanced due diligence (EDD) for higher-risk customers is especially […]

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Model Validation

As defined in the Federal Reserve SR 11-07 and the Office of the Comptroller of the Currency Bulletin 2011-12, “Supervisory Guidance on Model Risk Management,” Section V: “Model validation is the set of processes and activities intended to verify that models are performing as expected, in line with their design objectives and business uses. Effective […]

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