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#1226100 - 08/02/09 11:10 PM Annual Board Reporting
Tocomply Offline
Platinum Poster
Joined: Nov 2004
Posts: 650
I know there is a requirement to give the board an annual update of BSA in the company, but I cannot fine it anywhere. Can someone help me locate it?

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BSA/AML/CIP/OFAC Forum
#1226142 - 08/03/09 01:06 PM Re: Annual Board Reporting Tocomply
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
There is no such legal requirement. The closest you will get is the fact that your BSA/AML & OFAC programs should be supported by a current risk assessment. That's per the BSA/AML Examination Handbook, not regulation.

There is no predetermined frequency for updating the risk assessment; it should be reviewed whenever one of the major elements on which it is based; i.e. products, services, customers, or geography change. For a low risk bank, updating it between on site exams is the minimal effort; e.g. every 18 months. However, I suggest you update it and report the results to the board at least annually.
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#1227629 - 08/05/09 04:45 PM Re: Annual Board Reporting Tocomply
Ted Dreyer Offline
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Ted Dreyer
Joined: Apr 2001
Posts: 2,245
What you might have been thinking about is an Exam procedure on page 34 of the BSA Exam manual that says examiners should: "Assess whether the board of directors and senior management receive adequate reports on BSA/AML compliance."

"Adequate" does not necessarily mean "annual", of course, but that may be the policy at your institution.

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