Three BSA/AML Errors to Avoid

Bank Secrecy Act and Anti-money Laundering (BSA/AML) enforcement is shaping up to be a hot compliance topic this year. We’ve heard from the NCUA that one of its supervisory priorities for 2018 will be BSA compliance. There are also some big changes coming in just a few months with FinCEN’s new customer due diligence and beneficial ownership requirements. What all this means is that you’ll want to pay particularly close attention to your BSA/AML program and procedures throughout 2018. To ensure your AML program is up to scratch, it’s helpful to learn from the mistakes of others. Several months ago, FinCEN and the OCC announced a $7 million civil money penalty against Merchants Bank of California for willful BSA violations. Looking at what went wrong can help you avoid similar mistakes.

In case you were wondering whether BSA/AML problems are really a big deal, that $7 million fine should give you a hint at the answer. Regulators are very serious about violations in this area, and if you think you can slip through the cracks, you may be in for a rude awakening. The best way to keep your institution out of the regulatory hot seat is to ensure that you’ve got an airtight BSA/AML program. Merchants Bank learned this the hard way, and looking at their mistakes can be helpful…

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