BSA/AML Audits

The Bank Secrecy Act (BSA) is a tool the U.S. government uses to fight drug trafficking, money laundering and other crimes.

To be in compliance with the Bank Secrecy Act, financial institutions are required to appoint a BSA officer responsible for ensuring that the organization has developed an appropriate BSA AML Audit program and that the program is adequately maintained. The BSA AML officer is required to complete interim testing of various BSA requirements, and then annually, financial institutions are required to complete an independent review of their BSA program.

Money service businesses that cash checks, accept cash to wire or convert cash into other financial instruments also need an independent BSA AML (anti-money laundering) audit.

Part of developing an effective BSA program is completion of a BSA/OFAC risk assessment to determine the adequacy of the monitoring and control processes pertinent to BSA and to OFAC sanctions, including determining the organization’s risk profile. Skipping this step can result in applying a “one size fits all” approach that renders the program ineffective to your business.

An annual BSA/AML review should include the procedures in the core sections of the FFIEC manual to ensure that the organization has an adequate BSA/AML compliance program commensurate with its risk profile. The specific procedures that need to be performed will depend on your organization’s BSA/AML risk profile, the quality and quantity of independent testing, your organization’s history of BSA/AML compliance and other relevant factors.

Because the BSA/AML rules continue to get more complex and adherence to them is critical, it is important to work with a knowledgeable specialist firm. TWHC has been providing BSA/AML audit services to its clients for over 15 years. Our reports are robust and designed to improve your compliance posture.

The value of our engagements comes from the knowledge transfer that takes place during the audit, as well as with the final report. Our clients find that their BSA programs have improved significantly as a result of correcting the findings resulting from our comprehensive reviews.

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