Qualified independent reviews provide reasonable assurance to organizations about the adequacy of critical programs and areas where they can improve. One crucial area that requires an independent review is the Bank Secrecy Act (“BSA”), Anti-Money Laundering (“AML”), and Office of Foreign Asset Control (“OFAC”) Program. Financial institutions are required to comply with various laws and key regulatory requirements aimed at reducing money laundering and illicit activities. BSA requires explicitly that a five-pillar program exists for monitoring, preventing, and/or mitigating BSA/AML/OFAC risks.

Asurity Advisors established the scope of the review with the client and strategically placed BSA/AML/OFAC experts on the engagement. Asurity Advisors initially reviewed key governance documentation, including policies and procedures, the program structure, and risk artifacts (e.g., risk assessments, key risk indicators, and Board and management reporting). Next, Asurity Advisors conducted one-on-one interviews with several stakeholders who were responsible for overseeing, managing, and executing the BSA/AML/OFAC Program. Deep-dive sessions with the BSA Officer, the Chief Risk Officer, and other key personnel then followed this critical exercise. Asurity Advisors later performed transactional testing on samples of Suspicious Activity Reports (SARs), the Customer Identification Program (CIP) requirements, and Customer Due Diligence (CDD) requirements under the Know Your Customer regulations. Finally, Asurity Advisors delivered a comprehensive report of findings and recommendations stemming from the review, which could be used by the organization to strengthen its BSA/AML/OFAC Program.

Reach out to Tim Stokes at tstokes@asurity.com for more information or learn about our Financial Crimes and Fraud Risk Advisory Services at www.asurityadvisors.com.