Introductory BSA/AML Examiner School, Providence, RI

Program Structures

Areas to incorporate: • A reporting line to the corporate compliance or other independent function • Educate the compliance staff on products and customer relationships • Resolution process • Internal Controls

Program Structures

Centrally managed programs should establish: – Comprehensive risk management policies, procedures, and processes that address the entire organization’s spectrum of risk – Provide appropriate structure and guidelines – Determine reporting lines – Determine how roles and responsibilities are communicated across the bank or banking organization – Determine how data is captured from subsidiaries