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Supervision News Flash

August 2019

The BSA Coalition Highlights the Importance of Partnerships

tablet with word fraud

The annual BSA Coalition conference was held on June 27, 2019, and focused on Partnerships in AML to Support an Efficient and Innovative Approach. There were over 300 individuals from banks, credit unions, regulatory agencies and law enforcement in attendance. Each presentation emphasized the importance of partnerships to make Bank Secrecy Act (BSA) compliance more efficient and effective. 

The regulatory panel got things going by having a discussion around common BSA examination findings in an effort to have audience participants avoid similar issues. One common finding shared with the audience was when an institution has good policies and procedures in place, but they do not follow these in practice. Next, the agencies discussed the interagency guidance about resource sharing and innovation issued in the fourth quarter of 2018, and encouraged the audience to review these materials to see if these principles would be helpful for their institution. Finally, each of the regulators acknowledged their willingness to work with financial institutions to answer questions and help bankers understand regulatory positions on key issues.   

Other presenters and panelists echoed similar themes. The panel of law enforcement agencies discussed the invaluable partnerships developed with financial institutions to assist them with obtaining the information they need to conduct their investigations. They wanted bankers to remember they are not well versed in “banker’s talk” and that banker’s should add valuable, simplified information to suspicious activity report narratives. Likewise, the keynote address focused on how compliance staff should become a business partner or ally at their organization in order to change the perception of the compliance department.

The final panel, entitled “Strengthening Your BSA Program While Facing Corrective Action,” shared key thoughts for those institutions under a BSA enforcement action. The panel of bankers recommended focusing on long-term program sustainability rather than quick fixes.  Additionally, they counseled that it is important to have open lines of communication with both internal and external parties to ensure there are clear expectations around planning, timelines and deliverables. Finally, they ended with a wise observation that it is important to team morale that the members of the BSA team hear the good news when the corrective actions taken to address problems are successful. 

Visit for detailed information on the event.

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