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#120333 - 10/06/03 01:02 PM BSA
Anonymous
Unregistered

The bank's BSA officer is required annually to report to the BOD regarding the efficiencies of the bank's BSA program and shall recommend any appropriate changes in the program. Is there an additional requirement that the BOD is to approve the bank's BSA policy annually along with a review of the bank's exempt list?

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BSA/AML/CIP/OFAC Forum
#120334 - 10/06/03 07:45 PM Re: BSA
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
No. The policy does not need to be approved annually, nor do they need to review the exempt list.
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David Dickinson
http://www.bankerscompliance.com

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#120335 - 10/06/03 10:40 PM Re: BSA
Anonymous
Unregistered

I recently lost this battle with our internal audit firm. Our BSA policies will, in the future, be reviewed annually.

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#120336 - 10/16/03 12:05 PM Re: BSA
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
David is correct, there is no legal requirement that the BSA policy be approved by the board annually, although it is an excellent practice. There is also no requirement that the bank have an exempt list, let alone that the board approve it. By having the board approve the list, you are making board members directly responsible for something outside their expertise. They have enough BSA responsbility without making an upward delegation.

It's important to distinguish between legal requirements and recommendations, regardless of whether they are offered by auditors or examiners.
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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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