BSA / US Patriot Act Audit

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

Anyone?

Why not use the same procedures as the OCC?

You can find them here: OCC Compliance Publications

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.

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.

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

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.

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.

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.

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".

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?

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

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.

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