The ever-increasing importance of a robust BSA/AML monitoring system has become more than clear in recent years. However, an all-encompassing monitoring system often feels beyond the reach of the smaller financial institution. Resources are finite, and some institutions are left floundering when attempting to cover all their bases. What must your small financial institution do to determine whether its BSA/AML monitoring system is as sound as those applied by their far larger counterparts? In this two-part blog post, we’ll break down two essential elements that smaller financials must have in their BSA/AML monitoring systems.
Secret Weapon No. 1: Sufficiency
The first secret weapon is sufficiency. When we talk about sufficiency, we are talking about whether the monitoring completed in your institution, whether manually or through an automated system, completely covers all of the suspicious activities that should be monitored.
However, there are many other logistics that need to happen within an institution besides BSA/AML compliance. So, we also want to make the process efficient by completing a thorough AML review using the least amount of resources (like time and money) as possible.
The principles of sufficiency apply whether the institution has robust automated software or relies on a single employee conducting manual monitoring. The following are three areas to address when determining your program’s sufficiency.