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Scoped to your institution. Non-negotiable in substance.
Risk assessment. An enterprise BSA/AML and OFAC risk assessment methodology, quantitative and qualitative, producing bank-wide, product-level, and partner-level residual risk conclusions that drive the rest of the program.
Governance and documentation. Board-approved BSA/AML and sanctions policies, supporting standards and procedures, and the document hierarchy that holds them together: governance charter, taxonomy, approval authority matrix, renewal cycle, change management, and regulatory horizon scanning.
Internal controls. CIP, CDD/EDD, and beneficial ownership; transaction monitoring and sanctions screening design and tuning governance; SAR and CTR decisioning and filing governance; 314(a)/314(b), funds transfer recordkeeping and Travel Rule; OFAC screening, blocking, and reporting. For sponsor banks: partner due diligence, risk rating, ongoing monitoring, and offboarding criteria.
BSA Officer and Board reporting. KRI/KPI dashboards, issues management and root-cause remediation framework, and Board- and committee-level management information that shows program health rather than activity counts.
Training. Role-based curricula for the Board, senior management, and first-line teams.
Independent testing readiness. A second-line monitoring, QA, and testing framework, with the evidence trail examiners and independent testers will ask for.
Scoped to your institution. Non-negotiable in substance.
Risk assessment. An enterprise BSA/AML and OFAC risk assessment methodology, quantitative and qualitative, producing bank-wide, product-level, and partner-level residual risk conclusions that drive the rest of the program.
Governance and documentation. Board-approved BSA/AML and sanctions policies, supporting standards and procedures, and the document hierarchy that holds them together: governance charter, taxonomy, approval authority matrix, renewal cycle, change management, and regulatory horizon scanning.
Internal controls. CIP, CDD/EDD, and beneficial ownership; transaction monitoring and sanctions screening design and tuning governance; SAR and CTR decisioning and filing governance; 314(a)/314(b), funds transfer recordkeeping and Travel Rule; OFAC screening, blocking, and reporting. For sponsor banks: partner due diligence, risk rating, ongoing monitoring, and offboarding criteria.
BSA Officer and Board reporting. KRI/KPI dashboards, issues management and root-cause remediation framework, and Board- and committee-level management information that shows program health rather than activity counts.
Training. Role-based curricula for the Board, senior management, and first-line teams.
Independent testing readiness. A second-line monitoring, QA, and testing framework, with the evidence trail examiners and independent testers will ask for.