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?
Financial institutions investing in their commercial and business lending departments often find that deals fall into three categories: easy approval, easy denial, or the gray area. Credit teams often get into trouble when dealing in the gray area due to internal policies, competitive pressures, and technology limitations. Use this checklist to identify the common credit analysis mistakes and how to avoid them.
Download to learn:
- Signs of ineffective credit policies or practices
- What analysts should not do in tight credit situations
- Key data fields that should be captured in credit process
With human trafficking generating $150 billion annually and 25 million victims worldwide, it’s no surprise that financial institutions are looking for new ways to stop these horrific crimes. Financial institutions continue to play a pivotal role in detecting and reporting trafficking, making them a crucial part of their community’s safety. While human trafficking typologies are sometimes difficult for financial institutions to detect, it is possible. For financial institutions to help detect human trafficking, it is important not only to understand how victims become victims but also to understand who the traffickers are. Download this checklist to learn key behavioral and transactional indicators that are human trafficking red flags to identify both victims and traffickers within your customer base.
Download this checklist to learn:
- Key human trafficking red flags to help identify potential victims in your customer base
- How to adequately monitor your transactions for trafficking, with examples of transactional red flags to look for
- Behavioral indicators to watch for, including the presence of a third party in transactions
- How the 2014 FinCEN guidance still applies today and the key indicators identified by FinCEN
Interested in learning more about trafficking and better understanding what to look for in your own community? Watch our webinar Human Trafficking – Close to Home.
Remain Compliant While Preparing to Bank Cannabis
As cannabis continues to be legalized by states across the country, more financial institutions are seeking guidance on how to bank cannabis-related businesses while staying compliant with their regulators. This checklist compiles some essential concepts into a quick one pager to help you ensure that your AML/CFT program is fully prepared to handle this change successfully.
Download to learn:
- How to adjust customer due diligence
- When to conduct risk assessments
- The need for an exit plan
- The importance of an open dialog with your front line and examiners
