Advisory to U.S. Financial Institutions on Promoting a Culture of Compliance BSA/AML shortcomings have triggered recent civil and criminal enforcement actions — FinCEN seeks to highlight the importance of a strong culture of BSA/AML compliance for senior management, leadership and owners of all financial institutions subject to FinCEN’s regulations regardless of size or industry sector.
While this advisory does not change any existing expectations or obligations toward BSA/AML requirements; nor is it intended to change or otherwise interpret regulatory expectations or obligations that financial institutions may have outside of the BSA. It is, however, designed to specifically emphasize the following:
• Leadership Should Be Engaged
• Compliance Should Not Be Compromised By Revenue Interests
• Information Should Be Shared Throughout the Organization
• Leadership Should Provide Adequate Human and Technological Resources
• The Program Should Be Effective and Tested By an Independent and Competent Party
• Leadership and Staff Should Understand How Their BSA Reports are Used
Understanding and communicating the context and the purpose of FinCEN’s BSA/AML regime is equally important to a financial institution’s culture as understanding its underlying requirements, and financial institutions should consider including such information as part of their ongoing training requirement.
TRC Interactive can help your staff understand the significant importance of the BSA/AML requirements as well as how the information in BSA reports is used. Our BSA training courses are tailored to job description and are supported by additional information requirements including Anti-Money Laundering, USA PATRIOT Act, Customer Identification Program, Suspicious Activity Reporting, and Office of Foreign Assets Control. To learn more, contact us at email@example.com or (800) 222-9909.
The complete FinCEN advisory is available HERE.