Expanded Overviews and Procedures - Bank Secrecy Act/Anti-Money Laundering Examination Manual

Bank Secrecy Act (BSA)Federal Financial Institutions Examination Council (FFIEC)Anti-Money Laundering

Objective: Assess the organization's enterprise-wide program for BSA/AML compliance through the holding company or lead financial institution.

Similar to the approach to consolidated credit, market, and operational risk, effective control of BSA/AML risk may call for coordinated risk management. An enterprise-wide BSA/AML compliance program coordinates the specific regulatory requirements throughout an organization inside a larger risk management framework. Such frameworks seek a consolidated understanding of the organization's risk exposure to money laundering and terrorist financing across all activities, business lines, or legal entities. For example, the holding company or lead financial institution may have a centralized function to evaluate BSA/AML risk; this may include the ability to understand world-wide exposure to a given customer, particularly those considered high¬risk or suspicious, consistent with applicable laws.

Many organizations, typically those that are larger or more complex and that may include international operations, implement an enterprise-wide BSA/AML compliance program that manages risks in an integrated fashion across affiliates, business lines, and risk types (e.g., reputation, compliance, or transaction). Some larger or more complex organizations may decide to manage their risks by developing enterprise-wide approaches to their BSA/AML compliance program. Such programs manage risk at both operational and strategic levels.

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