The regulatory requirements in regards to the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) have greatly expanded. Federal and state regulators have placed great scrutiny on financial institutions' BSA/AML compliance programs. Our professionals are Certified Anti-Money Laundering Specialists (CAMS) and receive continuous training to remain up to date on the current focus and emphasis of regulators as well as any regulatory changes affecting your institution. Mercadien offers a variety of services in this area including:
One of the "four pillars" of an effective BSA/AML compliance program is an independent review. Our independent review is risk-based and tailored specifically to your financial institution. Our audit program follows closely the Federal Financial Institutions Examination Council (FFIEC) BSA/AML Manual that meets federal and state regulators' expectations. The core procedures of the review encompass your financial institution's Office of Foreign Asset Control (OFAC) program, Customer Identification Program (CIP), enhanced due diligence of deposit accounts, and independent transactional testing, among others. Expanded procedures regarding international correspondent banking, trade finance activities, and the like will be dependent on the products and services offered by your financial institution.
Many financial institutions have implemented software to assist in the execution of the BSA/AML program. This software typically includes transaction monitoring, account profiling, account risk rating, OFAC scanning, and CTR/SAR reporting. The trap into which many financial institutions fall is not performing validation procedures of the interfaced data to ensure that the software is properly capturing and analyzing the data. Lack of validation can cause your financial institution to inadvertently fail to file a CTR or SAR, as well as miss a potential individual listed on OFAC's specially designated national's list. Our professionals can perform software validation procedures for your institution either during an independent review or as a separate engagement.
Your financial institution may be asked to perform a review of prior transactions as part of a look-back review. Transactions need to be analyzed for potentially suspicious/suspect activity in order to determine if a SAR is required. Our professionals possess the knowledge to work with your financial institution to identify such patterns. The engagement will be customized to meet the specific needs of your institution.