March 2, 2017 - Barack Ferrazzano Client Alert

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Action Items

• Consider using the new BSA/AML Compliance Tool as an enhancement to help self-assess your BSA/AML compliance procedures and processes.
• Although the BSA/AML Compliance Tool is voluntary, regulators may incorporate its elements into future examinations. Thus familiarity with the BSA/AML Compliance Tool may ease future exam preparation.
• BSA/AML risk is always evolving and banks need to continually assess these risks.

The New CSBS BSA/AML Compliance Tool

The Conference of State Bank Supervisors recently released a BSA/AML Compliance Tool to help banks self-assess their BSA/AML compliance procedures. A link to the announcement can be found here, and a link to the Tool and its instructions can be found here.
The Tool is meant to be flexible to fit each bank’s unique BSA/AML risk profile and the constant evolution of BSA/AML risk. Although the Tool is voluntary, its elements may be incorporated (consistent with other compliance tools developed by the regulators) into future exams and banks should consider preparing for its eventual adoption as best practices.

We Can Help You

We often work with our bank clients to help them with their BSA/AML issues and help them prepare for their regulatory exams. Please contact us if you are interested in discussing how the Tool may affect your current BSA/AML compliance and risk management program, or if you have any questions regarding new developments in the BSA/AML area.

References

• CSBS State Financial Regulators Release BSA/AML Compliance Tool for Industry
  https://www.csbs.org/news/press-releases/pr2017/Pages/013117.aspx
• CSBS Job Aids - BSA/AML Self-Assessment Tool
  https://www.csbs.org/regulatory/resources/Pages/JobAids.aspx

• Client Alert - CSBS Releases New BSA-AML Compliance Tool.pdf