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#292018 - 12/22/04 04:04 PM BSA / US Patriot Act Audit
Anonymous
Unregistered

Last year I used the BSA / AML audit program found in the bankers tools section of Bankers Online for my audit. This year the OCC has said that they are going really beat BSA / US Patriot Act. Is anyone else using these programs? Are they enough?

Thanks

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Audit
#292019 - 12/23/04 08:44 PM Re: BSA / US Patriot Act Audit
Anonymous
Unregistered

Anyone?

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#292020 - 12/23/04 08:52 PM Re: BSA / US Patriot Act Audit
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,255
Galveston, TX
Why not use the same procedures as the OCC?

You can find them here: OCC Compliance Publications
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#292021 - 12/23/04 08:59 PM Re: BSA / US Patriot Act Audit
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
We used the OCC procedures. We haven't had a review yet, that is due in the spring, but the best we could do was incorporate their procedures at this point.

Good luck.
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My opinion is mine only- not my employer's!


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#292022 - 12/24/04 02:43 PM Re: BSA / US Patriot Act Audit
AnnRoy Offline
Platinum Poster
AnnRoy
Joined: Jun 2002
Posts: 771
South
I submitted the BSA audit workprogram on BOL tool about 1 1/2 year ago but now I use the FDIC's exam procedures that was released this summer. I suggest using your regulator's exam procedures.
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#292023 - 12/24/04 02:55 PM Re: BSA / US Patriot Act Audit
Anonymous
Unregistered

three years ago the OCC recommended that we use their exam manual as the basis of our BSA exam, whe have used it since without any comment

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#292024 - 12/27/04 06:55 PM Re: BSA / US Patriot Act Audit
Anonymous
Unregistered

I used the OCC BSA/CIP exam procedures. We are examined by the Federal Reserve. They just reviewed our audit and findings and were quite pleased with our procedures and findings.

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#292025 - 12/27/04 08:53 PM Re: BSA / US Patriot Act Audit
happyauditor Offline
Platinum Poster
happyauditor
Joined: Nov 2004
Posts: 808
NY
I am starting a BSA/PATRIOT Act audit as well and thought the best approach would be to use the regulator's (OTS, OCC, etc.) examination procedures as a starting point.
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* My opinion is not necessarily that of my employer.

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#292026 - 12/29/04 07:13 PM Re: BSA / US Patriot Act Audit
Anonymous
Unregistered

Once I was criticized by an examiner citing that their program is not an "audit program" but a "work program". I didn't quite understand the criticism, but it has made me somewhat hesitant to take and use their programs.

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#292027 - 12/29/04 09:42 PM Re: BSA / US Patriot Act Audit
AnnRoy Offline
Platinum Poster
AnnRoy
Joined: Jun 2002
Posts: 771
South
Well that doesn't make sense but coming from an examiner...who knows!!!! It would make sense to start with their "workprogram" and adapt the procedures to your bank's products, services, procedures, etc. (you get the picture).

I use the FDIC's BSA procedures and have not been criticized to date from an examiner for using their "workprograms".
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CAMS

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#292028 - 02/04/05 08:26 PM Re: BSA / US Patriot Act Audit
Anonymous
Unregistered

I am in the process of performing an aml audit. However, I don't know what the scope period seems to be and apparantly neither does anyone else. Does anyone know what the scope period for the aml audit is? Is it Jan-Dec of the previous year?

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#292029 - 02/07/05 02:12 PM Re: BSA / US Patriot Act Audit
DeeQ Offline
10K Club
DeeQ
Joined: Dec 2002
Posts: 40,760
Turnpike Exit 10
I would think it depends on when your last one was done. Mine run from June to June.
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Get your facts first, then you can distort them as you please. - Mark Twain

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#292030 - 02/07/05 02:16 PM Re: BSA / US Patriot Act Audit
hawksfan Offline
100 Club
Joined: Mar 2004
Posts: 114
Iowa/Illinois
We used the OCC BSA/CIP exam procedures. We are regulated by the FRB and they were extremely happy with the procedures we performed. They were just here in December.

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#292031 - 02/08/05 02:22 PM Re: BSA / US Patriot Act Audit
Anonymous
Unregistered

Have you had an examiner come in and look at your information and did not comment on the scope period?

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