Regulators expect compliance with the standards established in the model risk management guidance (MRMG) (Federal Reserve SR Letter 11-7, OCC Bulletin 2011-12; FDIC FIL 22-2017) as well as the April 9, 2021, Interagency Statement on Model Risk Management for Bank Systems Supporting Bank Secrecy Act/Anti-Money Laundering Compliance. This guidance relates to systems or models used […]
Financial institutions are facing increased regulatory pressure on Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures, particularly regarding inherently higher-risk customer types. CDD is critical to identifying and monitoring customers involved in higher-risk activities. Identification of higher-risk customers starts at account opening and your account opening procedures should incorporate this due diligence. Some
When dispositioning alerts from our automated BSA/AML monitoring system, how much information is enough?
Answer: TCA continues to see examiner scrutiny on alert resolution. When documenting a response to an alert, it does not need to be as in-depth as an investigation narrative; however, it must explain the who, what, where, when, why, and how. This creates continuity for other BSA staff, examiners, and auditors to understand how you