02/07/2005
One of the hand outs from the Bank Secrecy Act Compliance Management Webinar regarding exemptions indicates that the law requires a documented annual review for listed companies, subs of listed companies, eligible not-listed businesses, and payroll customers. However, in reading 31 CFR 103.22(d)(4)on the surface it appears to only require annual reviews of eligible non-listed businesses and payroll accounts. My question is: Are documented annual reviews required for listed companies and their subs?
01/31/2005
I'm the Internal Auditor of a community bank and will really appreciate your help with this. I'm working on the BSA Internal Audit and was trying to see if the FDIC/State requires for all employees to complete their BSA training, regardless of their department? We have a very good compliance program and training but it seems that some of the Loan department has not finish or even started with their online BSA training. Should I include as a recommendation to make sure that all employees complete their BSA training or should I write it up as violation? If you advise me to write it as a violation, give me good arguments because I have a stubborn Compliance Officer. Once again I would like to thank you for your time and assistance.
01/17/2005
In the answer given by Ryan Rasske on "AML Requirements Upon Identifying an MSB", he stated, "It is up to the bank to conduct the proper due diligence on their MSB customers and ensure they are complying with the law." We are in the process of determining what our responsibility is as a bank to ensure that our customers are complying with the law. What specifically do we need to be doing to be sure that we are using "proper due diligence"?