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The Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC) and the Office of Thrift Supervision (OTS) monitor banks and savings associations regarding the Bank Secrecy Act (31 CFR 103). A risk based approach to designing your Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) programs are the most efficient and cost effective way to ensure a well designed and compliant program. According to the Federal Financial Institutions Examination Council (FFIEC) the scope of an examination should begin with a review of the bank's BSA/AML risk assessment. If the bank has not developed a risk assessment, the examiner must complete a risk assessment. Associated Risk Group can help you with your BSA Risk Assessment.

We can assist your bank with a written BSA Program that includes:

1. A system of internal controls to ensure ongoing compliance including written policies and procedures to detect and prevent money laundering;
2. A designated individual to coordinate/monitor BSA compliance (BSA compliance officer);
3. Conduct independent testing of BSA compliance and
4. Training of appropriate personnel.

Our advisors can evaluate your AML Program and recommend procedures designed to detect and/or prevent money laundering activities and will address compliance with applicable anti-money laundering laws and regulations. Associated Risk Group can identify high-risk products, customers, businesses, and foreign countries associated with money laundering. A customized BSA/AML risk assessment will help your bank reduce time spent on low risk customers and products while maximizing your resources on activities with higher risk and reporting requirements.

Also, a bank is required by the USA Patriot Act §326 to have a Customer Identification Program (CIP). The CIP must document the identification and verification of the identity of any customer who opens an account (12 CFR §103.121). The CIP requirements include:

1. CIP must be a part of the bank's Anti-Money Laundering Program (AML);
2. Approved by the board;
3. Tailored to the bank's size, location and type of business; and
4. Notice must be given by the bank it verifies identity and why.

Banks are required to submit reports and/or retain records of various types of transactions and activities including:

1. Large currency transactions (CTR) by its customers;
2. Certain cash purchases of monetary instruments by its customers;
3. Known or suspected crimes and suspicious activity reports (SAR); and
4. Certain wire (funds) transfers.

Associated Risk Group is able to share best practices developed over years of experience and assist in creating and customizing a BSA/AML Program that meets your bank's specific needs.