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 Part 1 of this two-part post, we discussed the first secret weapon vital to the smaller financial institution’s BSA/AML monitoring systems: sufficiency. This week, we’ll examine the second and final essential element.
Secret Weapon No. 2: Efficiency
If sufficiency is the first secret weapon a smaller financial institution must employ as part of a sound BSA/AML monitoring system, the second is efficiency. Efficiency in AML monitoring is achieved when the institution is using the proper amount of resources needed to complete the task. For smaller institutions looking to make their AML monitoring more efficient, the secret may lie in the creation and use of level and trend reports.
When talking about level reports, we are referring to reports that display information of the current levels of AML monitoring completed. For larger institutions with automated systems this may be easier, as the list of information to collect comes out of the AML system itself, including the number of generated system alerts, the number of resulting investigations, and subsequent SARS.
With manual systems, knowing the right information to collect and analyze can be less clear. Using the information collected from automated systems as a guide, here are foundation elements of what we would recommend the information on level reports might look like.