The Bank Secrecy Act. For many, just reading those words can create feelings of nausea—and with good reason, given the prevalence of huge fines or cease and desist orders for BSA failures lately. However, it is precisely during such times when institutions can ill afford to let down their guard. Comptroller of the Currency Thomas J. Curry put it this way: “the Bank Secrecy Act is a key element in the fight against illegal drugs and terrorism… Meeting the challenges of the future will require increased diligence on the part of the industry and government alike.”
With avoiding penalties and fighting major crimes seemingly riding on compliance with BSA, it’s easy to feel overwhelmed and queasy. Add to that the issues heralded by the evolving nature of currency (we’re looking at you, Bitcoin), and you have a recipe for potential disaster—or at the least, a very burnt-out compliance officer.
However, as Curry adroitly points out, “the same technologies that can be exploited for illicit purposes can also be employed to combat [these activities]. Perhaps the time has come to explore these sources of technology as a means of…reduc[ing] the significant costs and burdens imposed on banks and other financial institutions.”3 Clearly, the time for half-measures has passed. It’s time to immerse your institution in the capabilities of technology, because you can rest assured that those who threaten your BSA security are already doing the same.
Using a cloud-based system of compliance reviews can make your compliance officer more effective by unburdening him or her from the time-consuming task of monitoring operations. It’s an approach we’ve developed here at AffirmX. We do this by using our cloud-based system to request various materials related to BSA (such as training documentation, the written OFAC policy, wire transfer logs, etc.) and reviewing these documents for compliance with rules and regulations. Furthermore, we offer timely and informative compliance reference tools, such as our online Risk Management Manuals and periodic regulatory updates. Not only can we alleviate the load of your compliance officer, AffirmX’s competitive pricing can reduce the significant costs associated with compliance.
We’ve written before about improving your BSA/AML automated system and how you need to evaluate a lot more than just the number of generated alerts. We provided the AML Rule Parameters Waterfall Model, created by our sister company, AdvisX, as a way for institutions to more easily visualize the process of analyzing its BSA/AML system. You can still access that tool for free. While this diagram remains quite helpful as a first step towards a more robust BSA/AML system, many institutions see the need to delegate their workload a little bit more.
It’s an approach that even has some financial institutions—rather than engage AffirmX for its full compliance services—utilizing our services for just preparing a BSA Independent Test. This audit leverages the power of AffirmX’s patented technology, which utilizes a cloud-based platform to make the exchange of data between your institution and our experts comfortably manageable, resulting in minimal disruption to your staff and a major pricing breakthrough for your compliance budget.
Despite its low cost, AffirmX’s BSA Independent Test encompasses a full scope of BSA and OFAC areas, including:
- BSA Policy and Procedures,
- Suspicious Activity Monitoring,
- Customer/Member Identification Program,
- Exemptions
- Currency Transaction Reporting,
- Member Due Diligence, and more.
We know you already see the need for a strong BSA program, but we hope to have illuminated the path to achieving it. Not only is improving your BSA program, avoiding potential penalties, and reducing prospective crime within your reach, but so is accomplishing these tasks in an efficient, budget-friendly manner.
To schedule a demo of AffirmX’s full platform, or for a cost proposal for a BSA Independent Test as part of the Basic Compliance Support Services package (starting at $2,500, depending on asset size), contact AffirmX’s client services representative, Mike Lane, at mike.lane@affirmx.com or 1-888-972-3624, ext. 7015.
