| Money laundering detection and prevention are critical elements of a financial institution's compliance program. An effective anti-money laundering strategy will help minimize exposure to transaction, compliance, and reputation risk and avoid the risk of fines and other enforcement actions by federal and state regulators.
BSA Independent Testing – ICS will verify compliance with the bank's BSA/AML policies and procedures, and test internal controls designed to prevent money-laundering activity. Our procedures will cover all major business lines, products and locations, including: |
- BSA/AML policies, procedures, and programs
- Qualifications of staff wholly or partially responsible for BSA compliance and day-to-day monitoring
- Scope, frequency and documentation of employee training program
- Board and senior management oversight
- Prior audit and examination findings and corrective actions
- Customer Identification Program (CIP) and account opening procedures (face-to-face, remote, and back-office)
- Correspondence with IRS or Treasury
- Enhanced due diligence for private banking and high-risk customers
- Suspicious activity detection and reporting
- Currency transaction reporting
- Identification of higher-risk activities, customers, and locations
- Currency shipments
- Wire transfers and other funds transfer activities
- Purchases and sales of monetary instruments
- Office of Foreign Asset Control
- Recordkeeping and retention requirements
- Information sharing requirements
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Independently from our BSA Compliance Review services, ICS will assist an institution to design a comprehensive and effective BSA Program, including: |
 CTR/SAR "Look Backs"- BSA/OFAC compliance risk assessments and necessary controls
- Monitoring and reporting procedures
- Training
- Record retention requirement
- Examination report review, responses, and corrective action plans
- Independent BSA/AML testing program development
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