BSA-AML Examiner School Case Study eBook

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BSA/AML Policy and Program

PARTY

ROLES AND RESPONSIBILITIES

annually; ● Promoting a strong culture of BSA/AML/OFAC compliance; ● Overseeing the Bank’s BSA/AML/OFAC program and assessing its effectiveness; ● Reviewing the Bank’s BSA/AML/OFAC risk assessment at least annually; ● Assigning responsibility and accountability for coordinating and monitoring day-to-day compliance with the BSA/AML Officer; ● Reviewing BSA/AML/OFAC compliance reports, including the annual independent testing of the BSA/AML/OFAC program; ● Reviewing the scope and results of regulatory examinations or correspondence relating to the Bank’s BSA/AML/OFAC program and addressing any key issues resulting from such examinations or letters; ● Reviewing a summary of the Bank’s suspicious activity reporting and other AML-related metrics quarterly; and ● Reviewing reporting on the comprehensive state of BSA/AML/OFAC compliance and any significant emerging issues at least annually and receiving updates on significant issues as needed.

The Management Risk and Compliance Committee is responsible for: ● Promoting and implementing a strong culture of BSA/AML/OFAC compliance;

Management Risk and Compliance Committee (MRCC)

● Receiving reporting from the BSA/AML Officer; ● Reviewing this Policy/Program and recommending approval to the Board; ● Reviewing the Bank’s BSA/AML/OFAC risk assessment at least annually; ● Reviewing periodic compliance reports, including the state of compliance, risk assessment, testing and monitoring reports; ● Reviewing, approving, and overseeing Bank-wide

Board Risk and Audit Committee, with delegated authority pursuant to the committee’s charter.

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Confidential