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July 19, 2007
What Kind of BSA Problems Will Result in a C&D?
The Federal Banking Agencies -- FDIC, FRB, OCC, OTS, and NCUA -- issued a joint statement today setting forth "the Agencies' policy on the circumstances in which an Agency will issue a cease and desist order to address noncompliance with certain Bank Secrecy Act/Anti-Money Laundering ("BSA/AML") requirements".
The Statement reiterates the four key BSA requirements:
- Internal Controls
- Independent Testing
- Designated BSA/AML Officer
- Training
The Statement also restates what one former FDIC Regional Director used to call the "bigger stick" process, that is, the bank regulators will start politely but escalate to an increasingly bigger stick until they get the attention of the financial institution's board of directors. Another no brainer is the Statement's reminder that one of the biggest no-nos is "failure to correct a previously reported problem with the BSA Compliance Program".
Still, it's helpful for "transparency" purposes to review this reminder about how to stay out of trouble.
Link: http://www.fdic.gov/news/news/press/2007/pr07061a.html
(ag) July 19, 2007, in BSA/AML
July 19, 2007 in BSA/AML | Permalink
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