With the rampant fraud associated with the pandemic, the institution’s compliance staff may be considered the unsung heroes of the institution. Along with protecting the institution from steep fines and regulatory violations, the Bank Secrecy Act (BSA) staff protect the institution and customers by identifying and stopping illicit activity. Even with the stay at home orders, these responsibilities continue.
With lobbies closed to most foot traffic, in-person account opening has decreased, and online account opening has increased. Does your institution’s new account risk assessment reflect the change in account opening methods?
Similarly, customers are changing the way they access their accounts. There is less in-person account activity and more on-line and mobile banking, P2P payments, wires, and internet transactions. Have you identified and effectively managed these account access risks at your institution?
FinCEN issued two notices (March 16 and April 3) regarding COVID-19 and related potential illicit financial activity. Trends include imposter scams, investment scams, product scams, insider trading and most recently, fraud relating to the PPP program. Do you need additional assistance culling through regulatory guidance and ensuring that your institution is compliant?
Compliance Services Group is here to help. CSG staff are well versed in BSA requirements. Many of our auditors are BSA Compliance Specialists or Certified Anti Money Laundering Specialists and have extensive experience dealing with all aspects of BSA compliance.
If you have any questions, or are looking to schedule your next BSA audit, contact us.
Please be advised that CSG provides financial services compliance audit and consulting services to our clients. The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers. Since some of our employees are lawyers with an active bar license but are NOT engaged in the private practice of law, that Rule requires us to make disclosures clarifying that the services we perform may be law-related services, but they are not legal services. Because they are not legal services, those services and our relationship will not be governed by the Rules of Professional Conduct that guide the client-lawyer relationship, such as rules applicable to privileged communications and prohibitions of conflicts of interest. Notwithstanding this disclaimer, we will continue to govern our relationship with you using reasonable ethical and professional standards that are expected to meet your expectations.
