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#39157 - 10/28/02 02:58 PM BSA Audit frequency
Anonymous
Unregistered

How often is a BSA audit required to be done? I can't locate it in the reg anywhere.

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Audit
#39158 - 10/28/02 05:02 PM Re: BSA Audit frequency
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
Each regulatory agency has their own interpretation. Here is the FDIC's:
ยง326.8 Bank Secrecy Act compliance.
(c) Contents of compliance program. The compliance program shall, at a minimum:

(1) Provide for a system of internal controls to assure ongoing compliance;

(2) Provide for independent testing for compliance to be conducted by bank personnel or by an outside party;

(3) Designate an individual or individuals responsible for coordinating and monitoring day-to-day compliance; and

(4) Provide training for appropriate personnel.


Notice that their is no time frame mentioned.
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David Dickinson
http://www.bankerscompliance.com

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#39159 - 10/28/02 05:29 PM Re: BSA Audit frequency
Anonymous
Unregistered

Thanks, That is what I thought also. We had the OCC here last week and they commented that too much time had gone by since we last did a BSA audit.

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#39160 - 10/28/02 07:24 PM Re: BSA Audit frequency
BANNED BY BOL MANAGEMENT Offline
Platinum Poster
BANNED BY BOL MANAGEMENT
Joined: Oct 2002
Posts: 524
Once a year works well with that frequency noted in the BSA policy.

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#39161 - 10/28/02 09:02 PM Re: BSA Audit frequency
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
It is common to hear of annual audits and training but as I pointed out, this is not required. We provide audits and training for numerous banks. Often this is setup on an 18 month or even 24 month basis.
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David Dickinson
http://www.bankerscompliance.com

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#39162 - 10/28/02 09:20 PM Re: BSA Audit frequency
Maria Offline
Platinum Poster
Joined: Apr 2001
Posts: 502
Sylacauga, Al, United States
We are OCC also. I would recommend a full BSA audit be conducted annually. But CTRs, "high" risk accounts, KYC procedures, wire transfers, & a few others should be monitored quarterly on a small scale. Training should be conducted annually which includes money laundering, anti-money laundering, OFAC, Identity Theft, "suspicious" activity, and internal policies. also a method should be implemented to train "new" employees until the annual training is conducted.

I am "hard" on this reg. I take it too seriously. I hope this helps.

Opinions are mine not my employer.

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#39163 - 10/29/02 02:46 PM Re: BSA Audit frequency
OnTheEdge Offline
Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
Currently, I do a full BSA audit annually. Each BSA officer is required to monitor quarterly and submit a written report of the areas they reviewed (1) CTRs (2) TIN's (3) Recordkeeping on wire transfers and cash sale of monetary instruments (4) transfers between branches (5) procedures for tracking multiple transactions.
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The opinions expressed are mine and do not necessarily reflect those of my employer.

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#39164 - 10/31/02 11:35 PM Re: BSA Audit frequency
Tina A Sweet Offline
Diamond Poster
Tina A Sweet
Joined: Aug 2001
Posts: 1,033
Marysville, Ca.
I review my CTR's, SAR's and MIL quarterly, but complete a
overall BSA review that incompasses all aspects of BSA i.e. USA Patriot, AML, CIP, and BSA.
_________________________
Tina A Sweet-Williams
AVP Special Assets
mailto:tsweet@goldcountrynb.com

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