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#2021905 - 06/22/15 06:12 PM BSA Officer Auditing Departments for Compliance
NCCompliance Offline
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Are there any BSA Officer's out there that are auditing departments within their institution for BSA/AML/OFAC Compliance outside of the internal audit department? If so, what are you looking for in each department?

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#2021984 - 06/22/15 07:57 PM Re: BSA Officer Auditing Departments for Compliance NCCompliance
HappyGilmore Offline
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Pulling people out of the ditc...
in our institution, this role falls to Compliance Audit and Internal Audit, 2 separate areas, 2 independent reviews.
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#2021991 - 06/22/15 08:10 PM Re: BSA Officer Auditing Departments for Compliance NCCompliance
osucpa Offline
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I have not heard of any. My question would be what is the process if they find an issue?

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#2021994 - 06/22/15 08:12 PM Re: BSA Officer Auditing Departments for Compliance NCCompliance
rlcarey Online
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Yeah, why would the BSA department be involved in audit - are they properly trained??? How can they audit something for which they should be ultimately responsible?
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#2022059 - 06/22/15 10:12 PM Re: BSA Officer Auditing Departments for Compliance NCCompliance
Princess Romeo Offline

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You can monitor for compliance, but you cannot "audit" for compliance of an area for which you are responsible.

Monitoring for compliance means to review processes, transactions, etc. and make note of anything that does not comply with the regulation and/or internal policies and procedures. But the resulting report is NOT an audit report - more of an "FYI guys, we're slipping up over here" report.
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#2022071 - 06/23/15 12:55 PM Re: BSA Officer Auditing Departments for Compliance Princess Romeo
ACBbank Offline
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Originally Posted By Princess Romeo
You can monitor for compliance, but you cannot "audit" for compliance of an area for which you are responsible.

Monitoring for compliance means to review processes, transactions, etc. and make note of anything that does not comply with the regulation and/or internal policies and procedures. But the resulting report is NOT an audit report - more of an "FYI guys, we're slipping up over here" report.


This.
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#2022514 - 06/24/15 02:55 PM Re: BSA Officer Auditing Departments for Compliance NCCompliance
AMC Offline
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As BSA Officer I do not 'audit", however I do monitor all aspects of our program and those involved in the day to day processes. I report back to the department head any deficiencies that I might find. Primarily I'm looking for policies or procedures that are not being followed.

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#2027781 - 07/17/15 01:39 PM Re: BSA Officer Auditing Departments for Compliance NCCompliance
NCCompliance Offline
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Ok, so maybe using the word "Audit" in this post to bankers was a mistake.

Audit: an official inspection of an individual's or organization's accounts, typically by an independent body; a systematic review or assessment of something; conduct an official financial examination of (an individual's or organization's accounts).

We were told by a BSA/AML consultant that we (BSA Officer) should be "reviewing" and "sampling" internal departments such as Credit Card, RDC, ACH, etc on an annual basis (outside of formal "audits" and exams) to ensure they are following procedures. We should be "documenting" our "findings" and discussing changes with the department managers. Sure sounds like a "systematic review" or "assessment" to me but we'll go with the term "monitoring" for those in this string.

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#2027797 - 07/17/15 02:03 PM Re: BSA Officer Auditing Departments for Compliance NCCompliance
AnnRoy Offline
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NBBCompliance- I sent you a PM regarding your question.
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#2027806 - 07/17/15 02:17 PM Re: BSA Officer Auditing Departments for Compliance NCCompliance
BC78a Offline
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What your consultant is recommending is that you establish a monitoring and testing function, within your compliance department. This is an industry best practice at big banks.
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#2027809 - 07/17/15 02:20 PM Re: BSA Officer Auditing Departments for Compliance NCCompliance
edAudit Offline
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You are here
This is an industry best practice at big banks.

and midsize and small...
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#2027823 - 07/17/15 02:41 PM Re: BSA Officer Auditing Departments for Compliance BC78a
rlcarey Online
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Originally Posted By BC78a
What your consultant is recommending is that you establish a monitoring and testing function, within your compliance department.


Also commonly referred to as internal controls.
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