The Federal Financial Institutions Examination Council (FFIEC) BSA/AML Examination Manual (“FFIEC Manual”) outlines independent testing requirements and expectations. As stated in the FFIEC Manual, the purpose of independent testing is to assess the FI’s compliance with BSA regulatory requirements and assess the FI’s overall adequacy of the BSA/AML compliance program. The FFIEC Manual also indicates independent testing should be risk-based and evaluate the quality of the FIs risk management in relation to money laundering, terrorist financing, and other illicit financial activity risks.
While there is no regulatory requirement to establish the frequency of independent testing, industry best practice is to conduct an independent review every 12-18 months or when there are significant changes to the FI’s risk profile, systems, or processes.
AaSys Group’s goal is to identify and document potential compliance issues with your BSA/AML program in accordance with FFIEC Guidelines. Each audit is tailored to your individual risk profile, but at a minimum will include:
- An evaluation of the overall adequacy and effectiveness of your BSA/AML compliance program, including policies, procedures and processes.
- A review of your risk assessment for reasonableness given your risk profile.
- An evaluation of management’s efforts to remediate past audit or exam violations and deficiencies.
- A review of training for adequacy, and completeness.
- A review of the effectiveness of your suspicious activity monitoring systems used for BSA/AML compliance.
- An assessment of your overall process for identifying and reporting suspicious activity.
- Appropriate risk-based transaction testing to ensure compliance with recordkeeping and reporting requirements (i.e., SARs, CTRs, CTR exemptions, CIP, 314(a) requests, funds transfers, and monetary instruments).
- An assessment of the integrity and accuracy of reports used in monitoring for BSA/AML compliance.
Our testing will also cover pertinent sections of the USA PATRIOT Act and requirements specified through the Department of Treasury’s Office of Foreign Assets Control (OFAC).