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#1923241 - 05/14/14 07:03 PM BSA Officer??
Compliance Audit Offline
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Is it mandatory that the person responsible for compliance with BSA laws in a Bank be an officer?

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BSA/AML/CIP/OFAC Forum
#1923267 - 05/14/14 07:23 PM Re: BSA Officer?? Compliance Audit
manimal Offline
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This is from the FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual

https://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_007.htm


Originally Posted By:
BSA Compliance Officer

The bank’s board of directors must designate a qualified individual to serve as the BSA compliance officer.34 The BSA compliance officer is responsible for coordinating and monitoring day-to-day BSA/AML compliance. The BSA compliance officer is also charged with managing all aspects of the BSA/AML compliance program and with managing the bank’s adherence to the BSA and its implementing regulations; however, the board of directors is ultimately responsible for the bank’s BSA/AML compliance.

While the title of the individual responsible for overall BSA/AML compliance is not important, his or her level of authority and responsibility within the bank is critical. The BSA compliance officer may delegate BSA/AML duties to other employees, but the officer should be responsible for overall BSA/AML compliance. The board of directors is responsible for ensuring that the BSA compliance officer has sufficient authority and resources (monetary, physical, and personnel) to administer an effective BSA/AML compliance program based on the bank’s risk profile.

The BSA compliance officer should be fully knowledgeable of the BSA and all related regulations. The BSA compliance officer should also understand the bank’s products, services, customers, entities, and geographic locations, and the potential money laundering and terrorist financing risks associated with those activities. The appointment of a BSA compliance officer is not sufficient to meet the regulatory requirement if that person does not have the expertise, authority, or time to satisfactorily complete the job.

The line of communication should allow the BSA compliance officer to regularly apprise the board of directors and senior management of ongoing compliance with the BSA. Pertinent BSA-related information, including the reporting of SARs filed with FinCEN, should be reported to the board of directors or an appropriate board committee so that these individuals can make informed decisions about overall BSA/AML compliance. The BSA compliance officer is responsible for carrying out the direction of the board and ensuring that employees adhere to the bank’s BSA/AML policies, procedures, and processes.
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#1923384 - 05/15/14 01:19 PM Re: BSA Officer?? Compliance Audit
joser Offline
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Joined: Sep 2005
Posts: 68
NJ
No -- the BSA Officer is not required to be a corporate officer as well.

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#1923467 - 05/15/14 04:39 PM Re: BSA Officer?? Compliance Audit
devsfan Offline
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But he/she must have the authority to do the job so usually that would call for an officer title.

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#1923470 - 05/15/14 04:42 PM Re: BSA Officer?? Compliance Audit
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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If a bank uses officer titles, not giving one to the BSA officer says something.
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#1923719 - 05/16/14 01:38 PM Re: BSA Officer?? Kathleen O. Blanchard
Elwood P. Dowd Offline
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Next to Harvey
Agreed.

The now obsolete FDIC guidance indicated that the BSA Officer was required to be a senior officer and have the power to make and implement policy. I always thought they got that right.
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