BSA/AML Examination Manual - ffiec

Developing Conclusions and Finalizing the Examination — Examination Procedures
Management has not assessed, or has not accurately assessed, the bank’s
BSA/AML risks.
Management is unaware of relevant issues.
Management is unwilling to create or enhance policies, procedures, and
processes.
Management or employees disregard established policies, procedures, and
processes.
Management or employees are unaware of or misunderstand regulatory
requirements, policies, procedures, or processes.
High-risk operations (products, services, customers, entities, and geographic
locations) have grown faster than the capabilities of the BSA/AML compliance
program.
Changes in internal policies, procedures, and processes are poorly communicated.
3. Determine whether deficiencies or violations were previously identified by
management or audit or were only identified as a result of this examination.
4. Develop findings and conclusions and discuss them with the examiner in charge
(EIC) or examiner responsible for reviewing the bank’s overall BSA/AML
compliance.
5. Identify actions needed to correct outstanding deficiencies or violations, as
appropriate, including the possibility of, among other things, requiring the bank to
conduct more detailed risk assessments or taking formal enforcement action.
6. Discuss findings with management and obtain a commitment for improvements or
corrective action, if needed.
Preparing the BSA/AML Comments for the Report of
Examination
7. Develop a conclusion regarding the adequacy of the bank’s BSA/AML compliance
program. Discuss the effectiveness of each of these elements of the bank’s
BSA/AML compliance program. Indicate whether the BSA/AML compliance
program meets all the regulatory requirements by providing the following:
A system of internal controls.
Independent testing for compliance.
A specific person to coordinate and monitor the BSA/AML compliance program.
Training of appropriate personnel.
FFIEC BSA/AML Examination Manual 42 8/24/2007