ABA Banking Journal - November 2013 - (Page 43)
Sweating the small
-and the big-stuff
Exam teams stress not only BSA/AML details, but want to see results
BY STEVE COCHEO, EXECUTIVE EDITOR & DIGITAL CONTENT MANAGER
et's say, per doctor's orders,
a patient dutifully chooses a
diet and exercise regime in an
effort to lose weight. But a month
later, when the patient weighs in, the
needle hasn't budged a whit. Some
patients might swear that they've
been doing everything right. The doctors would just point out that scales
Other than getting a strong talking
to, the patient would pretty much be
on his own to decide what to do. The
doctor isn't going to go to the house
to see what a patient is really doing.
Bank examiners, however, do make
house calls. And in a roundup of
input from bankers, consultants, and
others, the word is your next BSA/
AML exam will be more exacting
than ever. First, examiners want to
see how well-equipped the bank is
with systems and procedures-a longstanding basic. Second, they want to
see how well those tools are working.
Third, they are stressing impact.
Harder-nosed attitude-for a reason
Consultant Nancy Derr-Castiglione,
one of ababj.com's "Common Sense
Compliance" bloggers, says exam
teams want to see more than efficient form-filling. Yes, that's important, she says, but it's a given. Today,
they are emphasizing efficacy-is the
BSA/AML program accomplishing
anything beyond stacking up forms?
And is the assortment of tools and
procedures being used properly and
with an eye toward current events?
The days of "buy the box and forget
it" are over.
"It's getting at the intent, rather than just the going through the
motions and checking off the boxes,"
ABA BANKING JOURNAL
Table of Contents for the Digital Edition of ABA Banking Journal - November 2013
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Pass the Aspirin
ABA At Your Service
ABA Banking Journal - November 2013