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Developing Conclusions and Finalizing the Exam > Developing Conclusions and Finalizing the Exam (2020)
Short Summary
This document provides guidance to examiners conducting BSA/AML examinations on banks. The objective is to formulate conclusions about the adequacy of the banks BSA/AML compliance program and its compliance with BSA regulatory requirements. Examiners should focus on whether the bank has established appropriate processes to manage ML/TF and other illicit financial activity risks, and whether the bank has complied with BSA requirements. Conclusions and findings should be presented in a written format for inclusion in the report of examination (ROE). The document also discusses the distinction between systemic or repeat violations and isolated or technical violations, and provides examples of each. Systemic violations involve substantive deficiencies or repeated failures to comply with BSA regulatory requirements, while isolated violations are limited instances of noncompliance within an otherwise adequate system. The document emphasizes the importance of documenting deficiencies or violations, discussing them with the bank, and determining the appropriate supervisory response. It also mentions that violations or deficiencies may lead to informal or formal enforcement actions. Overall, the document provides a framework for examiners to assess a bank’s BSA/AML compliance program and communicate their findings to the bank.
Whom does it apply to?
Examiners conducting BSA/AML examinations on banks.
What does it govern?
Formulate conclusions about the adequacy of the banks BSA/AML compliance program, relative to its risk profile, and the banks compliance with BSA regulatory requirements; develop an appropriate supervisory response; and communicate BSA/AML examination findings to the bank.
What are exemptions?
No exemptions are mentioned.
What are the Penalties?
No specific penalties are mentioned.
Jurisdiction
U.S. Federal Government