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Regulatory expectations around BSA/AML/OFAC compliance programs continue to increase with no relief in sight. Smaller institutions are not exempt from these pressures, contrary to what some senior management may believe, yet financial institutions are searching for new and more efficient ways to identify and report suspicious behavior. FinCEN’s requirements for a healthy culture of compliance provide valuable talking points when discussing AML automation with your leadership and board. This whitepaper is intended to assist BSA compliance professionals at smaller, less complex institutions make a case for automation by highlighting FinCEN’s opinion on what makes a healthy culture of compliance, enforcement actions against other community financial institutions, and the inefficiencies and deficiencies of a manual monitoring program.

In this guide, you will learn:

When it comes to transitioning to the current expected credit loss (CECL) model, some financial institutions are seeking a partner to aid with this regulatory change. Process outsourcing can help banks and credit unions focus on growth and investment in their communities. While there are many benefits to outsourcing the CECL calculation, it’s crucial to properly evaluate the right partner for your institution. This guide provides important factors and best practices when considering a process outsourcing partner for CECL.

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Now that CECL calculations are complete or nearing completion, what’s next? It is considered best practice to conduct model validations or have alternate controls to address the model validation control risks. Model validation identifies the weaknesses and limitations of a model for consideration as the model outputs are utilized. This guide covers the four core elements of an effective CECL model validation.

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A 7-Step Guide to Vendor Selection

Software, and the automation it provides, can allow financial institutions to scale and manage risk more efficiently, yet the process of buying new software is infrequent for many banks and credit unions.

This guide presents seven steps for evaluating software options and vendors, including many of the components of regulatory guidance on third-party relationships.

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Best practices to build and update your policies

A loan policy is a critical part of lending that ensures the bank or credit union operates within its prescribed risk tolerances. In today’s competitive and fast-changing lending landscape, an up-to-date loan policy may be more important than ever to properly reflect the institution’s particular needs and goals while allowing some flexibility to remain effective.

Although each institution’s process will differ slightly, the best practices outlined in this loan policy guide will enable your financial institution to understand and build an effective loan policy.


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Over the next few years, financial statements provided by customers could include stimulus proceeds that overstate their ability to make their loan payments. While stimulus programs were intended to keep business viable during the pandemic, some industry segments thrived and could use the funds received to reduce debt or bolster their cash position.

Understanding how to dissect the financial statements that you receive will be critical when assigning credit risk going forward. Below is quick guide to help you determine how to include some of the different stimulus programs that were offered during the pandemic.

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While providing financial services to cannabis-related businesses (CRBs) can be risky, it can also be advantageous. There is a substantial need for financial services by the cannabis industry, and there is a significant opportunity for banks and credit unions who choose to work with CRBs. It requires financial institutions to understand the industry’s nuances, closely monitor ongoing guidance and regulation changes, adequately safeguard the institution, and train staff accordingly. Even if cannabis is not legal in the financial institution’s state, customers in neighboring states still pose a risk. As more states continue legalizing cannabis, the onus is on financial institutions to complete thorough due diligence and know the members that cross state lines for services.

Ultimately, it is at the discretion of each financial institution on how they want to handle banking these businesses, knowing the state and federal laws. Understand the risks and learn how to stay compliant while banking CRBs.

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Providing financial services to cannabis-related businesses can feel like navigating through a haze of constantly changing regulations. View on our-demand webinar, Navigating Regulatory Haze: Banking Cannabis-Related Businesses and Managing Risk for additional insight on how to manage regulatory compliance and maintain a risk-based program.

Staffing Calculator Instructions

AML Staffing Calculator

Input the volume and time spent on activities within your AML compliance program and get a rough estimate of how many individuals are needed to ensure adequate coverage for all duties.

Step 1

Enter the average volume of each activity conducted each month in your BSA/AML department, such as the number of alerts or cases for review.

Step 2

Enter the average number of minutes per single activity. For example, how long it takes to clear one alert or review one case.

Some tasks related to suspicious activity monitoring are completed only once per year. For these activities, divide total time needed by 12 to estimate monthly minutes per activity.

Step 3

View the total hours per month spent on activities and number of full time employees (FTEs) required to complete the tasks of your AML compliance program. You may be surprised by the needs for your unique AML team.

Note: 90% Utilization Rate means 36 productive hours/week. 

Get The Extra Help You Need

Regulators must be confident that you are sufficiently staffed with the correct number and experience level of staff. 

Whether you're ready for a robust version of a staffing assessment to analyze your organization's resources or need of short- or long-term help with suspicious activity monitoring, we're here to help.

Get in touch today to see how our advisory services team can provide the support you need.


Abrigo's experts can help:

  • Review alerts, work cases, and prepare SARs to alleviate day-to-day operational challenges
  • Perform a comprehensive staffing assessment to ensure your team is set up to work as efficiently as possible
  • Assess and strengthen your program to give you more confidence heading into your audits and exams

“Working with Abrigo’s Advisory Services team gives me time to focus on other BSA projects that strengthen our program. We have confidence in knowing the alerts are being worked through in a timely and thorough manner.”

Davreen Dixon, JD, CAMS | Senior BSA Analyst, Capital Bank

Abrigo's AML Consulting Services

Dedicated experts to support your BSA/AML needs

Flexible Engagements with Abrigo

Our experts act as an extension of your AML Department and can help your institution regardless of who your current software or program management provider is. Learn how Abrigo is here to offer support with a variety of services that alleviate resource constraints, respond to regulatory feedback, and satisfy examiner expectations.


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The ag economy has changed drastically during COVID. Many ag borrowers bolstered their financial position, benefiting from stimulus programs, higher commodity prices, and stronger-than expected yields. What should ag lenders expect ahead? What are top-of-mind concerns for ag producers and ag lenders?

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Learn how to navigate mergers/acquisitions and AML compliance.

Mergers and acquisitions (M & A) are alive and well in the financial services industry. With institution consolidations on the rise, it’s essential to conduct proper due diligence. A compliant Anti-Money Laundering (AML) program can determine the success of a merger or acquisition. When two financial institutions come together, each AML and fraud compliance function will need to be consolidated. Integrating programs creates challenges for Bank Secrecy Act (BSA) Officers responsible for developing an integration plan while ensuring ongoing compliance with existing day-to-day tasks. In this whitepaper, discover why a compliant BSA/AML program is important in the consolidation of institutions. Understanding the mission-critical analysis, best practices, and risks of BSA/AML compliance – no matter what side of the transaction you are on – can determine the success of the transaction and assist in avoiding penalties.

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If M&A seems daunting, or if you are short-staffed, Abrigo Advisory Services can help. Learn more about how we can assist during this transition.