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BSA/AML Compliance by the Numbers

3 min read
May 25, 2017

Interested in learning more about the BSA/AML compliance landscape? You've come to the right place. It's essential to keep an eye on the trends in the industry. A recent survey of 160 compliance officers provided valuable insights about their BSA/AML compliance. Read on to see the results, and learn how you compare.

Bank Secrecy Act and anti-money laundering compliance is an important area of focus, especially as financial institutions prepare for the enhanced due diligence requirements that will take effect next year. (More on that in future posts!)

That's not the only reason it's a good idea to keep an eye on trends and patterns in compliance. Maintaining a good understanding of the industry is essential for managing your risk.

[Free Resource: BSA/AML Compliance Risk Assessment Worksheet]

Our friends over at CBANC—the largest online network of verified bank and credit union professionals—recently conducted a survey about BSA/AML compliance programs. We're happy to be able to share the results of their analysis with you via the infographic below:

One point that jumped out was the size of the compliance team supporting the department head. Financial institutions with less than $500M in assets had one staff member or fewer on their BSA/AML compliance team. Financial institutions with $500M-1B in assets had between one and two individuals on their BSA/AML compliance team. Banks and credit unions with more than $1B in assets had two to three people on the BSA/AML compliance team.

Here are some other interesting statistics from CBANC's study:

  • Financial institutions with $500M-$1B in asset size filed, on average, 1,508 CTRs in 2016. That's more than 100 per month!
  • These same institutions filed on average 79 SARs in a year.
  • Almost 50% of respondents don't have software for BSA/AML fraud detection and more.
  • 96% of respondants do not accept marijuana-related business.

As we watch for changes in the regulatory landscape, we will also be paying attention to developing BSA/AML trends. That said, there are some basics that everyone should know about BSA/AML. Download this free mini BSA/AML risk assessment, and read on to learn about BSA/AML compliance basics.

The Four Pillars of BSA/AML Compliance

There are four pillars that every written BSA/AML compliance program needs to have:

  • Internal controls;
  • The designation of a BSA/AML officer;
  • A BSA/AML training program; and
  • Independent testing to test programs.

An effective BSA/AML program also needs a strong foundation to support these four pillars of compliance. So what is that foundation? A comprehensive understanding of your organization's structure and risk exposure.

The best way to gain this understanding is through a BSA/AML risk assessment. This will will consider the key risks, and check how well the compliance program manages them. 

A well-developed risk assessment will consider your policies, procedures, controls, monitoring, reporting and more. It will also help you focus future efforts on the areas of greatest concern.

This risk assessment can be conducted internally. There are also benefits to having a third party conduct it. Not only might it be more efficient - this third party likely sees many BSA/AML programs in a year, and so will be better equipped to spot areas of risk - it may be a great way to save time and internal resources.

If you're a member of a small compliance team, it may be particularly worthwhile to consider an external risk assessment. Time is precious, and having an outside partner conduct that risk assessment and create a report on the results can be helpful.

The fourth pillar of BSA/AML compliance, the independent review, is different from a risk assessment. It's a chance for an independent third party to evaluate whether the BSA/AML program is accurate. It is also based upon the risk assessment findings.

This internal party can be external or internal, as long as they are independent from the BSA/AML functions.

Some institutions may opt to have the external party who conducts the risk assessment also conduct the independent review, to maximize efficiency and leverage their understanding of your business. 

Ncontracts Viewpoint: If you do decide to leverage a third party compliance consultant, Ncontracts is here to help. Our CAMS- and CRCM-certified consultants provide risk assessments, independent reviews, training, monitoring, and even build a program from the ground up. Our goal is to work with you to improve your compliance program and reduce your risk. 


Are you a member of CBANC? How do you manage compliance as a team of one? What other information could we provide to make your BSA/AML compliance management even better? We'd love to hear from you. Click here to get in touch.


Related: What Is A Compliance Management System And Why Your FI Needs One

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