Financial institutions and regulators themselves are under increased scrutiny after the collapse of Silicon Valley Bank and Signature Bank of New York. And given risks in the current banking environment, regulators have pledged a tougher stance and more aggressive supervision.
Four areas likely to receive additional examiner focus during upcoming credit union and bank exams are:
- Interest rate risk
- Liquidity risk
- Credit risk
- Operational risk
Use this checklist to make sure you are on top of these key focus areas.
Commonly known as the CFPB 1071 Rule, upcoming requirements to be finalized in 2023 by the Consumer Financial Protection Bureau (CFPB) will represent the most significant effort of data collection and reporting for financial institutions in nearly 50 years.
This checklist provides lenders with seven steps to prepare for compliance with this new rule.
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The passing of the Anti-money Laundering Act of 2020 (AMLA) is the first important step in overhauling the Bank Secrecy Act, and what we know is that not all sections of the Act have been finalized. FinCEN has been charged with much of the development and implementation of regulations in support of AMLA, which will take time. It is more important than ever that financial institutions keep current on the progress and prepare for regulator questions — the sooner, the better. AML/CFT programs should align with new expectations and requirements as they roll out. For now, what should a financial institution do to prepare?
Download this checklist to see what you can do to be prepared:
Preparing for a regulatory BSA/AML exam? Getting ready for examiners can seem overwhelming, but organizing your checklist of pre-exam tasks will help build confidence before your BSA/AML examination begins. Banking examiners evaluate BSA/AML program compliance relative to the institution’s risk profile, so a critical aspect of being ready for regulators is to make sure you can show a risk-based approach to BSA/AML efforts.
Use this checklist of suggested key steps to ensure a smooth process for your next BSA examination, regardless of risk profile.
Download this BSA/AML exam prep checklist to learn:
- Areas of your BSA/OFAC policy, risk assessment, and business continuity plan to review prior to your regulatory BSA/AML exam
- Key questions to ask when reviewing your AML program quality assurance
- Other steps your financial institution should take to ensure you are prepared for your next BSA examination
Interested in learning more about preparing for regulatory exams? Download our Guide for successful BSA/AML programs, or view our webinar BSA Exam Preparation 101: Hot Topics to Expect During Your Next Exam.
Need help preparing for your next BSA/AML examination? Learn how our BSA/AML consultants can enhance your readiness by conducting risk assessments, reviewing policies and procedures, conducting audits, and more.
Elder financial exploitation (EFE) and elder fraud continue to be serious crimes in the United States. EFE crimes are rising at an alarming rate. With no signs of dissipating, financial institutions are in a unique position to detect and report these crimes. With 1 in 10 individuals over the age of 60 falling victim to this crime, it is critical for financial institutions to know the behavioral and financial red flags of elder financial abuse and ramp up training programs.
Download this checklist to learn:
- Potential indicators of EFE identified by law enforcement, FinCEN and the National Council on Aging
- Financial and behavioral red flags
- FinCEN requested SAR additions
Detect and prevent EFE at your financial institution. View our webinar Elder Financial Exploitation – The Hidden Crime.
Non-Bank Financial Institutions (NBFIs) must adhere to Bank Secrecy Act (BSA) regulations and have an anti-money laundering (AML) program commensurate with the risk profile of their business model. Customer due diligence (CDD), commonly known as the fifth pillar of Bank Secrecy Act (BSA) compliance, is the cornerstone of a robust BSA/AML compliance program. In addition to general onboarding procedures your organization requires, it is also critical to know your customers or with whom and where they conduct business. Your CDD program should be aligned with and supported by your risk assessment.
Download this checklist to learn:
- Steps in the CDD process that your organization should be performing
- When to conduct periodic enhanced due diligence
- Guidance on Enhanced Due Diligence, depending on the assessed risk of the customer
Looking for additional resources on AML compliance for your Non-Bank Financial Institution? Watch the complimentary webinar, AML Compliance and Sanctions Requirements for NBFIs, or learn more about how Abrigo can help all types of financial businesses as a true partner for your compliance program.
With mergers and acquisitions (M&A) and other institution consolidations on the rise, it’s essential to conduct proper due diligence. 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. Regulators expect that an institution’s AML compliance integrity will keep pace with its growth.
Executive management should take precautions to ensure that a strong culture of compliance, including BSA/AML, is reflected in their merger and acquisition plans. Compliance professionals must be prepared to communicate the high-risk operations, locations, products, services, and customers the target offers to management and any plans to mitigate that risk.
While not exhaustive, this three-step checklist can guide acquiring institutions to consolidate successfully and maintain AML best practices.
Download this checklist to learn:
- Steps for preparation and evaluation ahead of mergers and acquisitions, including a minimum set of questions for the M&A due diligence process
- Categories the acquirer should use for a comprehensive risk assessment of the target institution
- Critical areas that should be considered in consolidation plans during M&A
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.
Customer Due Diligence (CDD) is the cornerstone of a strong BSA/AML compliance program. In fact, CDD is commonly known as the fifth pillar of Bank Secrecy Act (BSA) compliance. In addition to general onboarding procedures required by your financial institution, regulatory expectation is that you know your customer, with relative certainty. It is also critical to know your customer’s customers, or with whom and where they conduct business. Periodic Enhanced Due Diligence (EDD) reviews should also be conducted for higher risk customers and entities.
This checklist outlines key elements to a strong CDD program, which should be risk-focused and aligned with your enterprise-wide risk assessment.
Download this checklist to learn:
- Steps for Customer Due Diligence to help strengthen your institution’s program
- Guidance on Enhanced Due Diligence, depending on the assessed risk of the customer
- Occurrences when further Enhanced Due Diligence should be conducted
Looking for additional resources on conducting due diligence at your financial institution? Register for the complimentary Abrigo webinar, Beneficial Ownership and Due Diligence: Stepping Up Your Institution’s Information Collection Practices.
As required by the Anti-Money Laundering Act of 2020 (AMLA), the Financial Crimes Enforcement Network (FinCEN) published its first-ever Priorities list for anti-money laundering and countering the financing of terrorism (AML/CTF) policy. Financial institutions can begin taking steps to prepare for the increased scrutiny in each of these published Priorities. Taking a proactive approach will show the examiners that the criticality is understood and taken seriously.
Download to learn:
- What financial institutions should take away from these Priorities
- Steps to take now to ensure preparedness across the pillars of BSA
- Ways to ensure each Priority has been incorporated into your institution’s BSA/AML program
Looking for additional insight into the published AML/CFT Priorities? Watch our webinar, FinCEN AML/CFT Priorities: What Do They Mean for Your Institution?
When purchasing new compliance software, financial institutions should carefully perform due diligence when comparing service providers. Once a decision is made and software implementation is complete, the Federal Financial Institutions Examination Council (FFIEC) recommends periodic ongoing monitoring of the service provider. Use this checklist to review fundamental steps to help your institution through the BSA compliance vendor selection and monitoring process.
Download this checklist to learn:
- Due diligence steps for selecting a compliance vendor
- Focus areas to review including financial statements, legal, and regulatory compliance
- Ongoing monitoring to perform once a vendor is selected
Discover key areas for your BSA compliance training program with our Introductory BSA Guidebook.