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#371191 - 06/09/05 01:40 PM BSA Officer - Independent of Management?
Risk Officer Offline
100 Club
Joined: Apr 2001
Posts: 205
Some of our people are hearing that the regulators are suggesting that the BSA Officer should be independent of management. The annual test, of course, should be independent, but I've never heard it recommended that the BSA Officer be "independent"...

Anyone else hearing the same thing?
Last edited by Risk Officer; 06/11/05 10:46 PM.
My opinions are just opinions.

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#371192 - 06/09/05 02:44 PM Re: BSA Officer - Indepdndent of Management?
FlBankerGal Offline
Joined: May 2002
Posts: 91
I was the BSA Officer up until last month. And yes, what you are hearing is true. The recommendation is that the BSA Officer be segregated from daily operational duties that would include CTR monitoring and such. In addition, with an increased focus on AML it is felt that someone with a more investigative background be the BSA Officer.

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#371193 - 06/09/05 02:49 PM Re: BSA Officer - Indepdndent of Management?
DeeQ Offline
10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
Well, I audit our BSA officer, and as long as I am independent of his functions, that was sufficient for my examiners.
Get your facts first, then you can distort them as you please. - Mark Twain

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#371194 - 06/09/05 08:35 PM Re: BSA Officer - Indepdndent of Management?
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
No question. Better to have you report to the full board or a board committee. They will criticize anything else!

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