Bank Secrecy Act / Anti-Money Laundering

FOS conducts annual BSA/AML audits for greater than 35 community financial institutions or trust companies.  Our professionals attend a minimum of 20 hours of continuing education each year.  Bank Secrecy Act, OFAC, and USA Patriot Act are included in the minimum education requirements.  In addition, several professionals have served in the capacity of BSA Officer prior to employment with FOS. 

Our compliance audit program addresses the provisions outlined in the Bank Secrecy Act (BSA), Office of Foreign Assets Control (OFAC), and the USA Patriot Act.  Our audit program is based upon the guidance published by the joint regulatory bodies in the FFIEC’s Bank Secrecy Act/Anti-Money Laundering Examination manual.  Our procedures are directed towards not only an evaluation of the applicable policies/procedures and the related internal controls, but also detailed procedures to verify their effectiveness.  Specific areas of coverage include: reportable transactions, exemptions, record retention, risk assessments, suspicious activity monitoring and collection activities, monetary instrument sales and recordation, OFAC validation of new accounts, existing accounts, and non-customer transactions, data integrity of information systems that provide data for BSA/AML reporting, training programs, customer identification procedures, FinCEN Requests, and customer signage.