Real or perceived, over the last several years regulatory expectations have been heightened. As we enter 2018, and embark in a new year, what can we expect regarding Bank Secrecy Act (BSA) reporting expectations? The BSA requires that financial institutions have AML Programs that are “reasonably designed” to maintain appropriate records and file certain reports involving currency transactions and a financial institution’s customer relationships. Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs) are the primary means used by banks to satisfy the requirements of the BSA.
As set forth in the introduction of the BSA, the regulations were originally intended to aid investigations into an array of criminal activities, from income tax evasion to money laundering. Law enforcement agencies have found CTRs to be extremely valuable in tracking the huge amounts of cash generated by individuals and entities for illicit purposes. SARs used by financial institutions to report identified or suspected illicit or unusual activities are likewise extremely valuable to law enforcement agencies.
The biggest failure of an AML Program is the failure to file or to adequately file SARs. As we begin a new year, it’s a good opportunity to assess BSA reporting expectations and to address the question of how to define a “reasonably defined” BSA/AML Program.
This insightful session will discuss the following points:
If you are having issues with registering online, please contact CBAO's Education & Training Coordinator, Lianne Simeone, (614) 610-1877.