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Bank Secrecy Act /
Anti-Money Laundering

The IRS' Bank Secrecy Act (BSA / AML) and the amendments made with the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001 for anti-money laundering (AML) implements additional tools to prevent, detect, and prosecute international money laundering and the financing of terrorism.

Banks, casinos, credit unions, insurance companies, money services businesses, and many other firms, regardless of their business or size, must implement a written AML program that is reasonably designed to achieve compliance with the requirements of the Bank Secrecy Act.

At a minimum, the four point AML program must consist of:

  • Incorporate policies, procedures and internal controls reasonably designed to assure compliance with the Bank Secrecy Act
  • Designate a compliance officer to assure day-to-day compliance with the program
  • Provide for ongoing training of appropriate personnel concerning their responsibilities under the program, including training in the detection of suspicious transactions
  • Provide for an "independent" review to monitor and maintain an adequate program

In achieving compliance with the BSA / AML, CounterStrike professionals also include (as appropriate):

  • Customer Due Diligence (CDD)
  • Know Your Customer (KYC)
  • Customer Identification Program (CIP)
  • Office of Foreign Assets Control (OFAC)
  • Currency Transaction Reports (CTR's) and Suspicious Activity Reports (SAR's)
  • Evaluation of automated monitoring systems & Management Information Systems
  • Adequacy of AML Risk Assessment procedures
  • Review of past audit reports to assess the efficacy of implemented changes

And a host of other areas from the Federal Financial Institutions Examination Council (FFIEC) and Financial Crimes Enforcement Network (FinCEN)

Let CounterStrike be your best defense for BSA / AML deferred prosecution agreements, fines and regulatory enforcement actions - contact us today!

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