Does anyone have a Quality Control Process in place within the BSA Department? If so, what is the sampling size % that is recommended. For example: for CTRs, SARs, alerts, etc. Thank you.

CTR's are prepared by tellers, we ARE quality control on them. If we had any exam criticism for errors perhaps we would consider a third pair of eyes. But we don't. A quarterly review of CTR's for suspicious activity though is a separate item. Also periodic checks on the number of CTR filings being stable is a good idea.
SARS are definitely prepared under dual control. Our system requires a second pair of eyes
On alerts, there are only two of us who work alerts, and we work a single queue. Therefore, since either of us might work an alert, or a repeat alert, our story is that constitutes an internal control. Or, you could periodically swap queues.

Like most things BSA, this is going to depend on the size and complexity of your institution and should be risk-based. Most banks are probably like Daisy and rely on the Branch to complete the CTR and BSA does 100% review.

Alerts can vary based on the bank. I have seen from X number per alert type/rule/worklist for small shops and defined % (most often I have seen 5%) per analyst for larger shops. This can increase an additional 5% for each analyst where errors are found in their documentation/dispositions. Cases and SARs are generally reviewed at 100% to ensure the SAR/No-SAR decision is properly documented.

Before any of that works, you must have a well documented alert and Case documentation methodology established with the actual elements you require to be reviewed and documented. It is also helpful to have a checklist of SAR requirements and line item instructions to do a proper SAR QC. Match SAR field elements to the narrative. Ask your internal auditor to walk you through an audit of a SAR and that will help you develop a review process.

Calmeida 2 - I sent you a PM.

Big Dog - do you have a QC program in your BSA shop?

I don't have a BSA shop since moving over to the consulting/audit side. I did have an informal one that was not well documented, but since it was a small shop and we had very few documentation issues, Auditors and regulators did not have any concerns.

We have two forms of QC at my place. We have a dedicated QC Unit which reviews all business accounts opened and a sampling of consumer accounts. A 100% review is somewhat out of the norm, but we don't open that many business accounts on a monthly basis and most of our branches cannot follow simple instructions, so it's warranted.

We have a QC function enabled for Tier 1 and Tier 2 reviews within the FIU. These reviews are done by the Team Leaders of the respective teams. All FIU QC reviews are done on a sampling basis.

QC for SARs and CTRs is coming as well. In my neck of the woods, there is a big push for banks to have two sets of eyes on everything.

Everything is relative...the size of your institution, number of employees, but particularly the type of activity. Given the actual purpose of the report, a box by box review of every CTR is a serious misallocation of resources. I would do it only when a regulator cited deficiencies in internal controls in the written report of examination, not a moment before and the agreement would only cover a period long enough to prove the deficiencies had been corrected. As for reviewing a percentage of CTRs on a regular basis, the smaller the number of CTRs filed, the greater the percentage should be sampled.

In terms of relative importance, new account documentation is at the opposite end of the spectrum. It's the foundation for a legal relationship that may last for decades and the source for due diligence information... Many small institutions require all account opening documentation to carry two sets of initials; e.g. sometimes the second review is in the back room within 24 hours. In others, CSR's at adjacent desks just swap packages of documentation throughout the day and review their work before it even gets to the backroom.