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Can you summarize Assessing the BSA/AML Compliance Program > BSA/AML Independent Testing (2020)?
Assessing the BSA/AML Compliance Program > BSA/AML Independent Testing (2020)
Short Summary
This document governs the independent testing program for assessing the adequacy of a bank’s compliance with BSA regulatory requirements and the overall adequacy of the BSA/AML compliance program. The independent testing should be conducted by the internal audit department, outside auditors, consultants, or other qualified independent parties. Banks without external auditors or consultants or internal audit departments may use qualified bank staff not involved in the function being tested. The independent testing should report directly to the board of directors or a designated board committee. The frequency of independent testing should be commensurate with the bank’s ML/TF and other illicit financial activity risk profile. Risk-based independent testing should evaluate the bank’s risk assessment, internal controls, information technology sources, systems, and processes. The independent testing should assess the bank’s compliance with BSA regulatory requirements and identify weaknesses or areas in need of enhancements. Violations, exceptions, or deficiencies should be documented, reported to the board of directors, and tracked for corrective actions. Examiners should review the independent testing scope, procedures, and findings to determine compliance with BSA regulatory requirements and independence. The independent testing should also evaluate suspicious activity monitoring systems and the overall suspicious activity monitoring and reporting process.
Whom does it apply to?
Banks
What does it govern?
BSA/AML Independent Testing
What are exemptions?
Banks that do not employ outside auditors or consultants or do not have internal audit departments may comply with this requirement by using qualified bank staff who are not involved in the function being tested.
What are the Penalties?
No specific penalties mentioned.
Jurisdiction
U.S. Federal Government