BSA/Anti-Money Laundering Evaluation


FRC conducts an independent evaluation of a financial institution’s success with recordkeeping and reporting and other anti-money laundering responsibilities related to the Bank Secrecy Act/Anti-Money Laundering regulations.

This service satisfies regulatory expectations that institutions perform an annual, independent evaluation of their BSA compliance program. More importantly, this review evaluates the effectiveness of the financial institution’s efforts to detect reportable currency transactions, to identify suspicious transactions, and to implement money laundering deterrence systems.

Our consultants follow examination procedures similar to those utilized by regulatory agency examiners. We review written BSA/AML policies and conduct transactional testing to determine the accuracy and timeliness of Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs). We are also available to assist the institution in establishing or evaluating its risk assessment programs.

In addition to transactional testing, our consultants evaluate established procedures to:

  • Respond to Section 314(a) requests
  • Comply with prohibitions against maintaining correspondent accounts with foreign shell banks
  • Comply with Office of Foreign Assets Control (OFAC) requirements and limitations
  • Exercise due diligence for correspondent or private banking accounts
  • Provide appropriate training to affected personnel
  • Transmit appropriate ‘travel information’ involving fund transfers
  • Identify the customer upon account opening (CIP)
  • Determine eligibility and grant exemptions from CTR filing
  • Classify and monitor high-risk customer account activity
  • Identify, monitor, and report currency transaction and/or suspicious activity
  • Adhere to record retention requirements
  • Monitor monetary instrument sales
  • Review Exempt Accounts
  • Monitor wire fund transfers

Throughout this engagement, our consultant is in constant communication with management regarding the progress of our review. At the conclusion of the review, we meet with management to discuss our findings, and to request clarification, when needed, with respect to specific files, and to offer suggestions designed to strengthen existing policies and procedures. As part of the engagement FRC also prepares a management report which summarizes the scope of the engagement and includes recommendations for enhancing overall regulatory compliance performance.


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Regulatory Bulletin: August 2017

August 21st, 2017 by rfriedman