Introductory BSA/AML Examiner School, Atlanta, CA
Program Structures
Areas to incorporate: • A reporting line to the corporate compliance or other independent function • Educate the compliance staff on products and customer relationships • Resolution process • Internal Controls
Program Structures
Centrally managed programs should establish: – Comprehensive risk management policies, procedures, and processes that address the entire organization’s spectrum of risk – Provide appropriate structure and guidelines – Determine reporting lines – Determine how roles and responsibilities are communicated across the bank or banking organization – Determine how data is captured from subsidiaries
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