BSA/AML Examination Manual - ffiec

Scoping and Planning — Overview
CORE EXAMINATION OVERVIEW
AND PROCEDURES FOR ASSESSING
THE BSA/AML COMPLIANCE
PROGRAM
Scoping and Planning — Overview
Objective. Identify the bank’s BSA/AML risks, develop the examination scope, and
document the plan. This process includes determining examination staffing needs and
technical expertise, and selecting examination procedures to be completed.
The BSA/AML examination is intended to assess the effectiveness of the bank’s
BSA/AML compliance program and the bank’s compliance with the regulatory
requirements pertaining to the BSA, including a review of risk management practices.
Whenever possible, the scoping and planning process should be completed before
entering the bank. During this process, it may be helpful to discuss BSA/AML matters
with bank management, including the BSA compliance officer, either in person or by
telephone. The scoping and planning process generally begins with an analysis of:
• Off-site monitoring information.
• Prior examination reports and workpapers.
• Request letter items completed by bank management. Refer to Appendix H
(“Request Letter Items (Core and Expanded)”) for additional information.
• The bank’s BSA/AML risk assessment.
• BSA-reporting database (Web Currency and Banking Retrieval System (Web
CBRS)).
• Independent reviews or audits.
Review of the Bank’s BSA/AML Risk Assessment
The scoping and planning process should be guided by the examiner’s review of the
bank’s BSA/AML risk assessment. Information gained from the examiner’s review of
the risk assessment will assist the scoping and planning process as well as the evaluation
of the adequacy of the BSA/AML compliance program. If the bank has not developed a
risk assessment, this fact should be discussed with management. For the purposes of the
examination, whenever the bank has not completed a risk assessment, or the risk
assessment is inadequate, the examiner must complete a risk assessment. Refer to the
core overview section, “BSA/AML Risk Assessment,” page 18, for guidance on
FFIEC BSA/AML Examination Manual 11 8/24/2007