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BSA Compliance Matters
Savvy compliance managers will remember that the USA Patriot Act makes BSA compliance as important as CRA compliance when it comes to getting an application approved. The act adds BSA as a factor for consideration in merger transactions. The agency must take into consideration "the effectiveness of any insured depository institution involved in the proposed merger transaction in combating money laundering activities, including in overseas branches." For details on this process, see FDIC's FIL-109-2001. This effectively means that institutions must have more than a written BSA program. The institution must be able to demonstrate that the program works.
Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 5, 5/02
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