“Next Steps After Receiving Criticism from the Bank Examiners”
The Client Situation:
A mid-sized bank based in New England received critical comments from bank examiners regarding its Bank Secrecy Act and Anti Money Laundering (BSA/AML) programs.
The GAP Approach:
The GAP Team was retained by the bank to:
- perform an assessment of its BSA/AML Policies and Procedures
- design and implement a Financial Investigation Unit to be responsible for continuous monitoring of suspicious activity
The Benefits:
The team was able to:
- identify several improvements needed in the bank’s policies
- work with management to implement new procedures
- train the bank’s team, including Board of Directors, in BSA/AML topics
- design and successfully implement a tailored Financial Investigation Unit to monitor transactions for suspicious activities
The policies, processes, training and internal controls designed for the bank enhanced its compliance with the requirements of the Bank Secrecy Act and U.S. Patriot Act and were the truthful response to the weaknesses once criticized by bank examiners. The bank passed all subsequent BSA examinations with no significant findings and is now fully self sufficient in BSA/AML compliance as a result of the program implemented by GAP.
“Being Proactive on Compliance”
The Client Situation:
An international bank operating in the United States retained GAP to proactively review the bank’s BSA/AML compliance program.
The GAP Approach:
The scope of the engagement included:
- policies and procedures review
- testing for effectiveness of the procedures
- controls review
- review of monitoring activities
The GAP Team performed the necessary reviews and a mock audit of the program.
The Benefits:
The GAP Team’s recommendations that arose from the review and audit work included:
- implement a new process for the bank’s Section 314(a) information gathering and response
- install a new due diligence procedure on suspicious wire activity
- recommend new risk-based procedures for the monitoring and filing of Suspicious Activity Reports (SAR)
- design and conduct regular training sessions with employees covering money laundering topics with examples of suspicious activities
Subsequent to this first audit, due to the thoroughness of the review performed and quality of findings, bank examiners placed reliance on GAP’s recommendations and postponed their BSA/AML review for the following cycle. In addition, GAP was retained by the bank to act as the independent auditor of the BSA/AML program. It established a periodic audit process to ensure continued compliance for the bank.
