The Bank Secrecy Act – BSA
The Bank Secrecy Act was originally passed in 1970 with the goal of combatting money-laundering activity in the United States. It has evolved over time to keep pace with new and emerging threats related to financial crime. The Bank Secrecy Act requires financial institutions (not just banks) to help the federal government detect and prevent money laundering, terrorist financing, and other illegal activities. It has grown to be one of the most important regulations and carries stiff penalties for non-compliance.
The Bank Secrecy Act outlines many methods financial institutions are to use to detect and prevent money laundering, terrorist financing, and other illegal activities. These include written policies and procedures, identification of customers and beneficial owners, filing required forms and/or other recordkeeping, suspicious activity monitoring, etc.
Criminals are always looking for new ways to lie, cheat and steal, and, as mentioned above, the BSA has had to evolve over time to keep pace with current threats, as well as new and emerging threats. For example, the USA PATRIOT Act of 2003 was passed in response to the terrorist attacks on September 11, 2001. This Act required financial institutions to implement written Customer Identification Programs. In 2016, FinCEN issued rules that contained explicit customer due diligence requirements and requirements to identify and verify the identity of beneficial owners of legal entity customers.
Some of the main requirements of the Bank Secrecy Act include Customer Identification Program (CIP), Customer Due Diligence (CDD), Currency Transaction Reports (CTRs), Suspicious Activity Reports (SARs), Information Sharing, Monetary Instrument Recordkeeping, Funds Transfers (wires) Recordkeeping, Beneficial Ownership, and more. It also deals with Money Service Businesses and Marijuana-Related Businesses.
The FFIEC’s BSA/AML Examination Manual was developed to guide examiners when conducting BSA exams and ensure consistency. More than that, it gives financial institutions insight into what the examiners are looking for when evaluating their BSA Programs. It covers things you won’t necessarily find spelled out in detail in the Regulation, for example, the need for a BSA/AML risk assessment. It is an invaluable resource for anyone involved in BSA.
BSA Training Resources
We are in the business of educating bankers, and quality training is our top priority. Our goal is to see you and your financial institution succeed! You can be assured that everything we do, from in-person training and webinars to our magazine and blog, it’s done in our signature, plain-English style.
In-person BSA training, whether it’s at one of our conferences or on-site at your financial institution, is as good as it gets. The benefits of face-to-face training vs. other mediums are immeasurable. Face-to-face communication not only allows you to “hear” the material but also to “see” it and “feel” it. This personal interaction with both the presenters and the other attendees/co-workers will stay with you long after the training ends. Another perk of in-person, on-site training is that it can be customized to your specific wants and needs.
If you prefer a little more flexibility as to when and where you receive training, our BSA webinars are a great solution. We have webinars devoted to specific BSA topics or the requirements as a whole that you can choose from. The shortened format of a webinar (1-2 hours) really allows us to go in-depth with a laser-like focus on certain areas of the BSA requirements. For example, if your Team is struggling with Currency Transaction Reports, we have a webinar devoted only to that topic. If you want training geared specifically to your Board of Directors, new employees, lenders, etc., we have webinars that will get you on the right track.
Our Banking on BCC Magazine is a must for any compliance professional. This monthly, subscription-based electronic magazine receives valuable compliance information each month. We cover a variety of lending, deposit, and BSA compliance topics, from recent developments to highlighting areas that have maybe fallen off your radar. Each month, in addition to great articles, we feature a Q & A Corner, highlighting a few compliance questions we’ve recently received. Regular features such as BSA Bits & Pieces, Management Minute, and a Training Spotlight exist.
The Monthly Connection is yet another way to stay up-to-date on issues related to collecting small business loan data and interacting with your peers in the compliance industry. While we talk about a wide variety of topics each month, there is ample time to ask questions of our experts and your peers. We have always said, “Compliance is not competitive.” and our Monthly Connection is a way for compliance people to help other compliance people.
We began discussing the proposal in our September 2021 Monthly Connection.
There is no one-size-fits-all approach to a financial institution’s training wants and needs. That said we do recommend some variety in the methods you choose. Variety will not only help your budget but will also give you different viewpoints. Maybe you attend an in-person conference every few years and then fill in any gaps with webinars. Maybe you follow our blog to monitor major regulatory developments and look to our magazine for more in-depth analysis. The point is, you can tailor training to your wants and needs.
External Section BSA Resources:
This manual is a necessary resource for anyone involved in BSA/AML compliance. While it is geared toward examiners, it provides great insight and guidance for developing and implementing your BSA/AML program.
FinCEN’s mission is to safeguard the financial system from illicit use, combat money laundering and its related crimes including terrorism, and promote national security through the strategic use of financial authorities and the collection, analysis, and dissemination of financial intelligence.
- Your Federal Regulator’s website: