Large Bank Supervision Forum eBook

Internal Use Only

Five Pillars of an effective BSA Program . . .

BSA Officer

CDD

Training

Pillars

Independent Testing

Internal Controls

99

© 2023 – FinPro, Inc.

Internal Use Only

The Internal Control program . . .

Policies, Procedures, and Processes

Manage, monitor, and control risk through

Suspicious activity monitoring, SAR filing, and recordkeeping

100

© 2023 – FinPro, Inc.