I'm interested in finding out where the BSA Officer position fits within your bank's organizational structure. If you choose, "Other," please feel free to post a reply to provide a little more information.

Thanks!

BSA Officer Posititon Poll
Compliance Department
Legal Department
Line Department (e.g. Retail, etc.)
Deposit Support Department (e.g. Bookeeping, etc.)
Other

I am a BSA Officer and also Security Officer. I work under the supervision of our CEO and report to our Board of Directors via the Audit Committee.

Our BSA Officer reports through the holding company Retail Support unit.

We designated the highest ranking officer we could get in the Operations Division because that was where we had the greatest concentration of BSA expense.

Our philosophy was that authority, accountability and budget must go hand-in-hand. If your business activity gave rise to regulatory responsibility, then you were accountable for compliance with those rules. Along with the duty, you got the clear authority to manage the function on behalf of the company and the budget to carry out your mission. The usual disciplines of internal audit and budget-performance-based compensation held your feet to the fire.

We did NOT want accountability for compliance to rest on the compliance officer, because the compliance department had no authority to control employees in other units.

I fully concur with Richard’s position and the supportive reasons provided by him that your institution should designate the highest-ranking officer in the Operations area of your bank to be the BSA Officer rather than including this additional responsibility along with the title to the Compliance Officer. One thing to consider especially when operating in a smaller shop is that your BSA Policy may include audit procedures and a call for independent testing to be performed by the bank’s compliance officer or the bank’s external auditor. This could also apply to the Security Officer’s position. I would find it somewhat hard for the Compliance Officer to be subjective in their audit findings if he/she performed this function on themselves if he/she were the Compliance, BSA and/or Security Officer.

FYI - I just responded to your BSA Poll that a line officer (retail) is BSA Officer. But research, some training, some monitoring, and SARs are handled by the Compliance Officer (me). The BSA Officer oversees the large cash transaction review and training.

The senior operations officer is the BSA officer at my bank.

Our Vice President of Operations is our BSA officer.

Adding to my last post - I forgot to mention that BSA duties had originally been assigned to the C/O (me) when that position reported to the senior operations officer. The reorg that changed my reporting line from Operations to Legal caused us to put the BSA duty back on Operations. My new boss's (general counsel) comment was something like, "...you can stay, boy, but that's got to go!". Her reasoning was that BSA is mostly a processing function and Operations was the most efficient processing unit we had.

Because BSA was at the top of our risk ratings, I continued to advise and support Operations and was never too busy to help with a problem or deal with regulators.

Thank you to everyone who responded. Almost 50% of the respondents said the BSA Officer position was located in the compliance department.

Thanks again!