Independent Banker - May 2019 - 20

PORTFOLIO
that the regulators have increasing
expectations for BSA [compliance] at
community banks and don't intend to
allow resource challenges to diminish
their performance, " says David
Bequeaith, president and managing
director of TIB-Bequeaith Banking
Solutions. " They have responded with
direction on what can and can't be
done to achieve those tasks, and that
is welcome. As an auditor for roughly
100 banks ranging from $100 million
to $13 billion [in assets], this clarifi cation
is useful. "
Each bank's risk assessment must
show that it has adequately identifi ed
the risk within its banking operations-products,
services, customers,
entities and geographic locations-and
incorporated the risk into the BSA/
AML compliance program. And each
bank must maintain a written BSA/
AML compliance program commensurate
with its respective BSA/AML risk
profi le that includes a system of internal
controls: independent testing of
BSA compliance; a designated person
or persons responsible for managing
BSA compliance (BSA offi cer); and
training for appropriate personnel.
Collaboration ideas
The interagency statement off ers suggestions
that parallel the requirements
of the BSA/AML program:
Q Internal controls: Community
banks may benefi t from a collaborative
arrangement to 1) review,
update or draft BSA/AML policies
and procedures; 2) review or develop
Upcoming compliance training
Look to ICBA's
Community
Banker University
for industryspecific
education
and
professional development
opportunities. Here are
some upcoming regulatory
compliance-focused events.
icba.org/education
BSA/AML Institute
Executive C-suite training,
compliance and BSA certification
May 14-16
Minneapolis
Compliance Institute
Executive C-suite training,
compliance certification and
compliance
June 9-14
Minneapolis
BSA/AML Institute
Executive C-suite training,
compliance and BSA certification
Aug. 5-7
Denver
Annual Current Issues/
Certification Conference
Leadership development,
information, executive C-suite
training, compliance, auditing.
Certifications: technology,
compliance, BSA, bank security,
auditing
Sept. 23-26
Minneapolis
Compliance Institute
Executive C-suite training,
compliance certification and
compliance
Sept. 29-Oct. 4
Nashville, Tenn.
Annual Current Issues/
Certification Conference
Leadership development,
information, executive C-suite
training, compliance, auditing.
Certifications: technology,
compliance, BSA, bank security,
auditing
Oct. 21-24
Charlotte, N.C.
BSA/AML Institute
Executive C-suite training,
compliance and BSA certification
Nov. 13-15
Dallas
risk-based customer identifi cation
and account monitoring processes;
or 3) tailor monitoring systems and
reports for the risks posed. Sharing
resources, such as databases, may
also be cost-eff ective.
Q Independent testing: Many community
banks have been challenged
to employ staff independent of the
day-to-day BSA/AML requirements
who are qualifi ed to perform meaningful
independent testing of the
program. Shared resources
may be a solution for some
banks.
Q BSA/AML training:
For some community
banks with small
staff s, and particularly
those
20 Q ICBA Independent Banker Q May 2019
http://www.icba.org/education
Independent Banker - May 2019

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