FinCEN Issues Advisory on Culture of BSA/AML Compliance
On August 11, 2014, the Financial Crimes Enforcement Network (FinCEN) issuedAdvisory FIN-2014-A007, which highlights the importance of financial institutions instituting and maintaining a strong culture of compliance for the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) rules.
There have been several recent enforcement actions against financial institutions for BSA/AML violations. FinCEN believes many of these enforcement actions could have been avoided had the institutions had strong compliance cultures.
According to FinCEN, a strong compliance culture is comprised of the following elements:
- Engaged leadership
- Compliance is not compromised by revenue concerns
- Information is shared throughout the institution
- Leadership has sufficient technological and human resources
- Effective compliance program
- Competent independent testing
- Understanding of how BSA reports are utilized by the government
CLA’s financial institution regulatory compliance team assists banks and credit unions nationwide in establishing regulatory compliance programs, conducting compliance testing, and training staff on regulations. Justin Robinson is a member of CLA’s regulatory compliance team and can be reached at justin.robinson@CLAconnect.com.
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