Does your financial institution ("FI") have a designated officer responsible for coordinating and overseeing the AML framework?

YES NO

Does your FI have an established risk-based approach for identifying and assessing risk within products, services, entities and geographic location?

YES NO

Has your FI issued guidelines and requirements for determining the appropriate level of enhanced due diligence necessary for various customer types that may pose a heightened risk of illicit activity?

YES NO

Does your FI regularly evaluate and modify transaction monitoring scenarios?

YES NO

Does your FI have procedures for considering account closure, particularly in instances where multiple SARs may have been filed on the same account or customer?

YES NO

Does your FI provide role and responsibility specific AML training?

YES NO

Does your FI participate in Section 314(b) Information Sharing Program?

YES NO

Does your FI have an Enterprise-wide process for communicating and reporting compliance issues and initiatives?

YES NO

Does your FI have an independent audit function of the BSA/AML compliance program?

YES NO

A designed BSA Officer is one of the 4 pillars of a robust BSA/AML program. The BSA Officer is responsible for managing all aspects of the BSA/AML program and the bank’s adherence to all relevant regulations. The BSA Officer must have the expertise, authority, resources, and time to satisfactorily administer the BSA/AML program.

A designed BSA Officer is one of the 4 pillars of a robust BSA/AML program. The BSA Officer is responsible for managing all aspects of the BSA/AML program and the bank’s adherence to all relevant regulations. The BSA Officer must have the expertise, authority, resources, and time to satisfactorily administer the BSA/AML program.

A risk-based approach is a cost efficient way to focus efforts and resources to areas of higher risk for money laundering. Additionally, the risk assessment methodology should be based on appropriate and well-supported risk criteria and employed consistently across all business lines.

A risk-based approach is a cost efficient way to focus efforts and resources to areas of higher risk for money laundering. Additionally, the risk assessment methodology should be based on appropriate and well-supported risk criteria and employed consistently across all business lines.

High risk customers should not all be defined or treated as posing the same level of risk. Customers such as, corporations; non-for-profits; non-bank financial institutions; and individuals, each require their own EDD criteria.

High risk customers should not all be defined or treated as posing the same level of risk. Customers such as, corporations; non-for-profits; non-bank financial institutions; and individuals, each require their own EDD criteria.

Many scenarios will generate excessive or unproductive alerts where suspicious activity is anticipated but none is found. Improving the effectiveness of a transaction monitoring system will reduce the number of unproductive alerts thereby helping to contain compliance costs.

Many scenarios will generate excessive or unproductive alerts where suspicious activity is anticipated but none is found. Improving the effectiveness of a transaction monitoring system will reduce the number of unproductive alerts thereby helping to contain compliance costs.

While there is no obligation to close an account on which a SAR has been filed, leaving an account open may subject a financial institution to enforcement actions and reputational risk.

While there is no obligation to close an account on which a SAR has been filed, leaving an account open may subject a financial institution to enforcement actions and reputational risk.

The training component of the BSA/AML program must be considered an on-going process with new employee’s being trained as they join and all employees kept up to date with regulations, money laundering trends, law enforcement advisories, and changes to the institution’s BSA/AML policies and procedures.

The training component of the BSA/AML program must be considered an on-going process with new employee’s being trained as they join and all employees kept up to date with regulations, money laundering trends, law enforcement advisories, and changes to the institution’s BSA/AML policies and procedures.

Information sharing under the 314(b) program provides several benefits including helping AML investigators form a more accurate assessment of a customer’s activity and aiding the SAR decision-making process. Additionally, financial institutions may be alerted to customers with potentially suspicious activities it may not have been previously aware.

Information sharing under the 314(b) program provides several benefits including helping AML investigators form a more accurate assessment of a customer’s activity and aiding the SAR decision-making process. Additionally, financial institutions may be alerted to customers with potentially suspicious activities it may not have been previously aware.

A framework for communicating compliance issues and initiatives improves coordination and integration across the institution. As a result, duplicative efforts among business lines can be avoided.

A framework for communicating compliance issues and initiatives improves coordination and integration across the institution. As a result, duplicative efforts among business lines can be avoided.

The use of AML subject matter specialists increases the likelihood of identifying potential weaknesses or deficiencies in a timely manner. This enables institutions to address deficiencies before they become systemic.

The use of AML subject matter specialists increases the likelihood of identifying potential weaknesses or deficiencies in a timely manner. This enables institutions to address deficiencies before they become systemic.


Disclaimer: This assessment tool highlights only certain key aspects of the BSA/AML compliance program and is provided solely for general informational purposes. This tool does not address all potentially relevant BSA/AML requirements or provide definitive guidance regarding the applicability of any provision of BSA/AML regulations to a particular financial or other type of institution.