Preparing for a regulatory BSA/AML exam? Getting ready for examiners can seem overwhelming, but organizing your checklist of pre-exam tasks will help build confidence before your BSA/AML examination begins. Banking examiners evaluate BSA/AML program compliance relative to the institution’s risk profile, so a critical aspect of being ready for regulators is to make sure you can show a risk-based approach to BSA/AML efforts.
Use this checklist of suggested key steps to ensure a smooth process for your next BSA examination, regardless of risk profile.
Download this BSA/AML exam prep checklist to learn:
- Areas of your BSA/OFAC policy, risk assessment, and business continuity plan to review prior to your regulatory BSA/AML exam
- Key questions to ask when reviewing your AML program quality assurance
- Other steps your financial institution should take to ensure you are prepared for your next BSA examination
Interested in learning more about preparing for regulatory exams? Download our Guide for successful BSA/AML programs, or view our webinar BSA Exam Preparation 101: Hot Topics to Expect During Your Next Exam.
Need help preparing for your next BSA/AML examination? Learn how our BSA/AML consultants can enhance your readiness by conducting risk assessments, reviewing policies and procedures, conducting audits, and more.
Banks and credit unions face a variety of challenges today, whether it’s increased competition, changing customer expectations, or greater regulatory burdens, to name a few. Increasingly, financial institutions turn to automation and technology to combat these challenges. However, resistance from inside the organization can stall the best plans for adopting technology.
What can you do when the staff members you need to help ensure the technology ROI are unenthused or resistant to changing old processes and technologies? Change management, the people side of change, can help secure staff support and strong technology adoption.
Download this checklist to help you frame your financial institution’s vision and get the most buy-in possible when adopting new technologies.
Learn:
- The importance of clear communication that clarifies the “why” behind the technology adoption
- Why it’s essential to choose the right people at your institution to be involved with changing processes or technology
- How software change management efforts can benefit from staff feedback
Check out other change management resources:
- Webinar – Technology adoption: The “people” side of change
- Whitepaper – Leading a successful software implementation
Elder financial exploitation (EFE) and elder fraud continue to be serious crimes in the United States. EFE crimes are rising at an alarming rate. With no signs of dissipating, financial institutions are in a unique position to detect and report these crimes. With 1 in 10 individuals over the age of 60 falling victim to this crime, it is critical for financial institutions to know the behavioral and financial red flags of elder financial abuse and ramp up training programs.
Download this checklist to learn:
- Potential indicators of EFE identified by law enforcement, FinCEN and the National Council on Aging
- Financial and behavioral red flags
- FinCEN requested SAR additions
Detect and prevent EFE at your financial institution. View our webinar Elder Financial Exploitation – The Hidden Crime.
Financial institutions must structure their compliance programs to be risk-based to ensure that AML/CFT compliance programs are reasonably designed to meet regulatory requirements. Understanding its risk profile enables the institution to apply appropriate risk management processes to the BSA program to mitigate and manage risk and comply with AML/CFT regulatory requirements. Although each institution’s risk process will differ slightly, the best practice steps in this AML/CFT risk assessment checklist will enable your financial institution to understand and justify its risk-focused compliance program.
Please note: This is not an AML/CFT risk assessment template, because each institution’s process will differ.
Download this checklist to learn:
- How to identify risk categories for your unique financial institution
- Areas to consider when performing analysis for each identified risk category
- Tips to help identify inherent vs. residual risk for each risk category
- Things to review to help assess OFAC risk at your institution (may be included in BSA risk assessment or a standalone document)
Looking for assistance enhancing your AML/CFT program? Learn how Abrigo’s experienced AML Advisory Team can identify your BSA/AML risk and evaluate the effectiveness of the controls in place.
Read more about How to Conduct an Exam-Proof BSA/AML Risk Assessment in our recent blog post.
Non-Bank Financial Institutions (NBFIs) must adhere to Bank Secrecy Act (BSA) regulations and have an anti-money laundering (AML) program commensurate with the risk profile of their business model. Customer due diligence (CDD), commonly known as the fifth pillar of Bank Secrecy Act (BSA) compliance, is the cornerstone of a robust BSA/AML compliance program. In addition to general onboarding procedures your organization requires, it is also critical to know your customers or with whom and where they conduct business. Your CDD program should be aligned with and supported by your risk assessment.
Download this checklist to learn:
- Steps in the CDD process that your organization should be performing
- When to conduct periodic enhanced due diligence
- Guidance on Enhanced Due Diligence, depending on the assessed risk of the customer
Looking for additional resources on AML compliance for your Non-Bank Financial Institution? Watch the complimentary webinar, AML Compliance and Sanctions Requirements for NBFIs, or learn more about how Abrigo can help all types of financial businesses as a true partner for your compliance program.
Slow decisions and frustrating loan application processes are among borrowers’ biggest gripes with banks and credit unions compared with online or alternative lenders. Many typical origination processes generate complaints from staff and management of traditional financial institutions, too.
Here are 10 frustrating aspects of the application and underwriting processes that your financial institution can avoid by switching to a loan origination system (LOS). How many of these do your lenders and analysts encounter every day?
Download to learn:
- 10 common frustrations in loan origination
- Alternative options for the biggest challenges facing lenders and analysts
- How to transform your lending and credit risk process for your customers and internal staff
With mergers and acquisitions (M&A) and other institution consolidations on the rise, it’s essential to conduct proper due diligence. Integrating programs creates challenges for Bank Secrecy Act (BSA) Officers responsible for developing an integration plan while ensuring ongoing compliance with existing day-to-day tasks. Regulators expect that an institution’s AML compliance integrity will keep pace with its growth.
Executive management should take precautions to ensure that a strong culture of compliance, including BSA/AML, is reflected in their merger and acquisition plans. Compliance professionals must be prepared to communicate the high-risk operations, locations, products, services, and customers the target offers to management and any plans to mitigate that risk.
While not exhaustive, this three-step checklist can guide acquiring institutions to consolidate successfully and maintain AML best practices.
Download this checklist to learn:
- Steps for preparation and evaluation ahead of mergers and acquisitions, including a minimum set of questions for the M&A due diligence process
- Categories the acquirer should use for a comprehensive risk assessment of the target institution
- Critical areas that should be considered in consolidation plans during M&A
If M&A seems daunting, or if you are short-staffed, Abrigo Advisory Services can help. Learn more about how we can assist during this transition.
As your BSA/AML monitoring output is tied directly to the data being imported into the system from the core, it is critical that the data quality being imported is correct and contains all the pertinent information to be included for reporting/monitoring purposes, OFAC and 314(a) requirements, etc. Data should be monitored and reviewed regularly to ensure any errors are corrected to provide better output for the BSA/AML monitoring system. This data integrity review checklist outlines steps to help you complete this task.
Download this checklist to learn:
- Key steps to get started with the process of reviewing data integrity
- Information to pull from your core/teller systems and BSA/AML systems
- Actions to take post-review to remediate any issues discovered
Learn how our expert BSA/AML consultants can help with your institution’s data integrity review.
Customer Due Diligence (CDD) is the cornerstone of a strong BSA/AML compliance program. In fact, CDD is commonly known as the fifth pillar of Bank Secrecy Act (BSA) compliance. In addition to general onboarding procedures required by your financial institution, regulatory expectation is that you know your customer, with relative certainty. It is also critical to know your customer’s customers, or with whom and where they conduct business. Periodic Enhanced Due Diligence (EDD) reviews should also be conducted for higher risk customers and entities.
This checklist outlines key elements to a strong CDD program, which should be risk-focused and aligned with your enterprise-wide risk assessment.
Download this checklist to learn:
- Steps for Customer Due Diligence to help strengthen your institution’s program
- Guidance on Enhanced Due Diligence, depending on the assessed risk of the customer
- Occurrences when further Enhanced Due Diligence should be conducted
Looking for additional resources on conducting due diligence at your financial institution? Register for the complimentary Abrigo webinar, Beneficial Ownership and Due Diligence: Stepping Up Your Institution’s Information Collection Practices.
When FinCEN issues advisories, financial institutions need to know what this means for them regarding their suspicious activity monitoring and reporting programs. FinCEN has identified financial red flag indicators of ransomware-related illicit activity. These indicators can be used in training front line staff as well as AML and fraud investigators.
While much of the cybercrime detected comes from simple techniques such as phishing, others are becoming more sophisticated and complex. Malicious software often encrypts data and prevents or limits users from accessing their system until a ransom is paid. This guide provides summarized examples of trends, typologies, and indicators of ransomware that financial institutions should be aware of, as identified by FinCEN.
Download to learn:
- Examples of different cybercrime and ransomware trends, including Double Extortion Schemes, “Big Game Hunting” Schemes, use of “Fileless” ransomware, and more
- Key indicators of ransomware-related illicit activity, including irregular transactions occurring between customers and organizations, customers showing limited knowledge of CVC yet purchasing CVC, and more
- The specific language to use when filing a suspicious activity report (SAR) for cyber events
Cyber attacks are the most significant threat to U.S. financial institutions. Learn more about what your institution can do to prevent and detect cyber fraud. View our blog, FinCEN Guidance on Cyber Fraud – Video.