BSA / US Patriot Act Audit

Posted By: Anonymous

BSA / US Patriot Act Audit - 12/22/04 04:04 PM

Last year I used the BSA / AML audit program found in the bankers tools section of Bankers Online for my audit. This year the OCC has said that they are going really beat BSA / US Patriot Act. Is anyone else using these programs? Are they enough?

Thanks
Posted By: Anonymous

Re: BSA / US Patriot Act Audit - 12/23/04 08:44 PM

Anyone?
Posted By: rlcarey

Re: BSA / US Patriot Act Audit - 12/23/04 08:52 PM

Why not use the same procedures as the OCC?

You can find them here: OCC Compliance Publications
Posted By: J2C

Re: BSA / US Patriot Act Audit - 12/23/04 08:59 PM

We used the OCC procedures. We haven't had a review yet, that is due in the spring, but the best we could do was incorporate their procedures at this point.

Good luck.
Posted By: AnnRoy

Re: BSA / US Patriot Act Audit - 12/24/04 02:43 PM

I submitted the BSA audit workprogram on BOL tool about 1 1/2 year ago but now I use the FDIC's exam procedures that was released this summer. I suggest using your regulator's exam procedures.
Posted By: Anonymous

Re: BSA / US Patriot Act Audit - 12/24/04 02:55 PM

three years ago the OCC recommended that we use their exam manual as the basis of our BSA exam, whe have used it since without any comment
Posted By: Anonymous

Re: BSA / US Patriot Act Audit - 12/27/04 06:55 PM

I used the OCC BSA/CIP exam procedures. We are examined by the Federal Reserve. They just reviewed our audit and findings and were quite pleased with our procedures and findings.
Posted By: happyauditor

Re: BSA / US Patriot Act Audit - 12/27/04 08:53 PM

I am starting a BSA/PATRIOT Act audit as well and thought the best approach would be to use the regulator's (OTS, OCC, etc.) examination procedures as a starting point.
Posted By: Anonymous

Re: BSA / US Patriot Act Audit - 12/29/04 07:13 PM

Once I was criticized by an examiner citing that their program is not an "audit program" but a "work program". I didn't quite understand the criticism, but it has made me somewhat hesitant to take and use their programs.
Posted By: AnnRoy

Re: BSA / US Patriot Act Audit - 12/29/04 09:42 PM

Well that doesn't make sense but coming from an examiner...who knows!!!! It would make sense to start with their "workprogram" and adapt the procedures to your bank's products, services, procedures, etc. (you get the picture).

I use the FDIC's BSA procedures and have not been criticized to date from an examiner for using their "workprograms".
Posted By: Anonymous

Re: BSA / US Patriot Act Audit - 02/04/05 08:26 PM

I am in the process of performing an aml audit. However, I don't know what the scope period seems to be and apparantly neither does anyone else. Does anyone know what the scope period for the aml audit is? Is it Jan-Dec of the previous year?
Posted By: DeeQ

Re: BSA / US Patriot Act Audit - 02/07/05 02:12 PM

I would think it depends on when your last one was done. Mine run from June to June.
Posted By: hawksfan

Re: BSA / US Patriot Act Audit - 02/07/05 02:16 PM

We used the OCC BSA/CIP exam procedures. We are regulated by the FRB and they were extremely happy with the procedures we performed. They were just here in December.
Posted By: Anonymous

Re: BSA / US Patriot Act Audit - 02/08/05 02:22 PM

Have you had an examiner come in and look at your information and did not comment on the scope period?