We are FDIC regulated and expecting a Safety and Soundness Exam soon. Does anyone have any recent experience as to the hot topics with recent examinations regarding the BSA component?

Our recent exam seemed to evidence a focus on training (for both the board and ALL employees [specific to their job responsibilities] and on SARs (having a process in place for employees to report suspicious activity and having process in place for monitoring, such as reports of transactions just under the 10,000 CTR reporting limit, as well as the $3,000 - $10,000 transaction over a period of time so as to reveal structuring).

This along with the usual review of policy and other aspects of the four pillars (internal controls, BSA Officer, Independent Review and Training)

Ongoing due diligence on our high-risk customers was one of our hot topics.