BSA/AML Examiner School eBook

Internal Use Only

FinCEN Priorities 1. Corruption 2. Cybercrime 3. Terrorist Financing 4. Fraud 5. Transnational Criminal Organization Activity 6. Drug Trafficking Organization Activity 7. Human Trafficking & Human Smuggling 8. Proliferation Financing

Internal Use Only

BaaS – Banking as a Service BaaS partnerships differ from traditional vendor relationships in a variety of ways, notably in that they can present substantially higher degrees of risk. Accordingly, fintech partner oversight will form the core of the Bank’s future Third Party Risk Managment program. The FI should develop robust governing documentation to support the program. In particular, policy and program documents relating to Bank’s fintech partner oversight program should clearly address: • Roles and responsibilities • Reporting lines (board oversight and governance) • Testing and ongoing monitoring • Risk assessments • Partner due diligence and onboarding • Contractual safeguards • Contingency plans • Internal and external audits