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#323107 - 02/28/05 12:53 PM
"New" OCC requirements for BSA/AML Program
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10K Club
Joined: Dec 2000
Posts: 21,293
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The OCC wants our BSA program to be all encompassing. It presently contains he overarching BANK policies and procedures on BSA, AML, CIP, OFAC, 314a and b, investigating suspicious activity, etc. that each line of business much comply with and semi-high level information on investigations, 314a and b, etc.
What they want is going to take careful wording to avoid needing the board every time we change a departmental procedure in the bank. They want all line of business policies and procedures that carry out the program, including OFAC, to be part of the program. They want all BSA unit procedures - down to the level of what is done to research 314a requests - to be part of the program.
This is not a recommendation. They say we must have one document that can be picked up that explains in one place how our bank complies with BSA, AML, KYC, OFAC, Patriout Act, etc. in one place.
We will probably incorporate much of the line of business policies and procedures via appendices with language carefully stating what needs board approval. I don't want to get into a situation where a simple procedural change can't happen until the board meeting.
The line of business info would include departments instructions to their staff for OFAC, CIP, etc.
Less than a year ago, the OCC found our program to be satisfactory.
Last edited by kaybee; 02/28/05 02:21 PM.
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#323108 - 02/28/05 01:30 PM
Re: "New" OCC requirements for BSA/AML Program
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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I think you have been victimized by doing too good a job; i.e. given the current emphasis on BSA they have to critcize something. I know of other national banks that don't have a BSA program anywhere near the sophistication level of yours, but they were not given the same target, only one higher than their current level.
There is no uniformity in what banks are being told, even if they have the same regulator. (Given that the OCC updated only a small portion of its published examination procedures, it's no great surprise that their examiners are offering inconsistent advice.) Another BOL poster shared a very sophisticated AML risk assessment with me the other day, but indicated it was not yet "perfected." I suggested that she should not make any attempt to perfect it, but to leave it "as is" to give the regulator something legitimate to talk about. I genuninely dislike games, but if I am forced to play I have no intention of losing.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#323112 - 02/28/05 04:40 PM
Re: "New" OCC requirements for BSA/AML Program
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Opposite ends of the country, but you were both were told you needed a "grid" to reflect BSA training? Sounds like they may have exam procedures, they have just not made them public.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#323115 - 02/28/05 07:47 PM
Re: "New" OCC requirements for BSA/AML Program
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Power Poster
Joined: Mar 2001
Posts: 5,063
Pennsylvania
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A couple of years back I did different training for different areas of the bank. Front line, deposit operations, wire, loan, finance, etc. I tried to tailor it to their function and get specific with procedures. I was told by an OCC examiner that my training was not sufficient because for example I did not cover CTR filing procedures with the accounts payable folks. He told me that everyone was to be trained on every aspect of BSA. We do online training now and it covers everything imaginable. When the OCC took a brief look at BSA during a safety and soundness exam last year, they were impressed with the training. I would love to ask one of them to take the exam, but that is kind of like poking a grizzly bear with a sharp stick......
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Knowledge is knowing what to say. Wisdom is knowing when to say it.
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#323116 - 02/28/05 08:17 PM
Re: "New" OCC requirements for BSA/AML Program
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Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
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Thomasj - that's interesting because I had one OCC examiner tell me that for example, people in our wire processing department do not need training on CTR filing procedures. Go figure.... BTW - it's okay to poke a grizzly bear with a sharp stick, but it has to be a very long sharp stick!!!!
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CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
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