Bsa compliance program template

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Overview Flow Charts. One Subscription. Programs for global organizations should incorporate the AML laws and requirements of the various jurisdictions in which they operate. For instance, a highly diversified banking organization may establish or maintain accounts using multiple legal entities that are examined by multiple regulators.

This action may be taken in order to maximize efficiencies, enhance tax benefits, adhere to jurisdictional regulations, etc. As appropriate, examiners should coordinate efforts with other regulatory agencies in order to address these challenges or ensure the examination scope appropriately covers the legal entity examined. As is the case in all structures, the audit function should remain independent.

In particular, allocation of responsibility should be clear with respect to the content and comprehensiveness of MIS reports, the depth and frequency of monitoring efforts, and the role of different parties within the banking organization e. In addition, a clear line of responsibility may help to avoid conflicts of interest and ensure that objectivity is maintained.

In some compliance structures, the compliance staff reports to the management of the business line. Boards of directors. While these percentages appear to be the same, the risks may be different. Examiners should not take any single indicator as determinative of the existence of a lower- or higher-risk profile for the bank.

The assessment of risk factors is bank-specific, and a conclusion regarding the risk profile should be based on a consideration of all pertinent information. The bank may determine that some factors should be weighted more heavily than others. For example, the number of funds transfers may be one factor the bank considers when assessing risk. Examiners should also assess whether the bank has considered all products, services, customers, and geographic locations, and whether the bank analyzed the information relative to those risk categories.