In my previous position as compliance analyst for a small community bank (assets roughly $4 million)I was put in the awkward position of checking my own work. All employees were required to work a rotating Saturday - my assignment was teller duty. My primary (compliance) tasks included checking daily cash reports for CTRs/AML, suspicious account activity research, formal audit (all aspects of bank operations), etc. To me, this was a huge conflict of interest. When broaching the subject with my manager, I was told it was OK - understood as a need because of the bank's size. How would examiners find?

I am the compliance officer and in addition to filing SARs I have recently become the "back-up" for BSA. When the BSA officer is out (vacation, I review the CTRs for accuracy and make sure they are sent on time. I also conduct a compliance review of the BSA annually.

I discussed this with the OCC and they said that was fine as long as I do not start making policy decisions and such. My samples will not include weeks that I handled the CTRs. SAR quality issues are reviewed by the chief auditor.