Federal financial regulators, along with the Treasury’s Financial Crimes Enforcement Network (FinCEN), have issued a statement on risk-focused Bank Secrecy Act/Anti-Money Laundering (BSA/AML) supervision. The statement does not include any new requirements but is intended to improve transparency into the risk-focused approach used for planning and performing BSA/AML examinations.
BSA/AML compliance programs should be risk-based and designed to identify and report potential money laundering, terrorist financing, and other illicit financial activity.
Federal regulators conduct risk-focused BSA/AML examinations and tailor examination plans and procedures based on the risk profile of each institution.
Common practices for assessing a risk profile include:
The information gained assists examiners in scoping and planning the examination and initially evaluating the adequacy of the BSA/AML compliance program. Regulators generally allocate more resources to higher-risk areas, and fewer resources to lower-risk areas.
In addition to the CompBlog, CUNA’s Compliance Community contains discussion boards and a number of other resources for credit union compliance professionals around the country.