Specialties
Risk assessments / CIP / OFAC
Due Diligence / Enhanced Due Diligence
BSA/AML Audits and Reviews
We bring practical, tailored BSA/AML solutions that allow you to meet your regulatory obligations and deliver essential support and training to foster a culture of compliance.
BSA/AML compliance never gets simpler.
Instead, year after year, we see more layers of complexity that make it more challenging for banks to comply with the Bank Secrecy Act and Anti-Money Laundering requirements.
Identifying, testing, managing, and controlling such risks require vigilance and someone to keep an eye on the minutiae.
We’re those eyes.
In addition, we bring you the knowledge and expertise to ease your team’s strain and workload and prepare you for your next exam. We also ensure that you have a solid plan in place to address your BSA/AML obligations for the long term.
Brian Crow, a nationally recognized BSA/AML expert who regularly presents at BOL’s BSA/AML Top Gun Conferences, leads TCA’s BSA/AML team.
That team comprises seven former bankers who are skilled at spotting and correcting the most common problems—inadequate systems, documentation, procedures, or staffing levels—and addressing the subtle, complex risks specific to your institution.
During engagements, we work collaboratively with your team and provide daily updates—something that’s invaluable in resolving challenges throughout the engagement.
We think it’s A Better Way than finishing a review and handing you a report with surprises and intimidating to-do lists.
You also can expect guidance from BSA/AML specialists through TCA’s RCM Hotline, routine check-ins that keep your program on track, and discussions about FinCEN updates and how they affect your compliance program.
Through this ongoing support and discussion, we help you nurture your bank’s culture of compliance and enhance your skills so that you can recognize and avoid regulatory minefields.
TCA offers A Better Way for you to comply with the Bank Secrecy Act's complicated obligations and related requirements.
Key Deliverables Include:
- Assessing the effectiveness of the design of your bank’s BSA/AML Program and testing the integrity as it relates to BSA/AML compliance requirements in accordance with FFIEC Exam Manual Standards.
- Measuring BSA/AML staff’s understanding of internal policies and procedures.
- Offering the Board of Directors perspective on the overall status of the BSA/AML Compliance Program.
- Developing conclusions about your BSA/AML compliance program's adequacy, reporting, and explaining our findings, and making recommendations on ways to improve your program's effectiveness.
BSA / AML Insights
AML/CFT Transaction Monitoring – Importance of Tuning Your AMS Model
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 […]
TCA’s Top 5 BSA/AML Concerns
The Bank Secrecy Act/Anti-Money Laundering area of compliance is always evolving. As an example, we are currently transitioning the name of this specialized area of compliance from Bank Secrecy Act (BSA) to Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) to coincide with the term’s examiners are now using within their documents and reports. […]
FinCEN Issues Final Rule for Beneficial Ownership Reporting
On September 29, 2022, FinCEN issued a final rule for Beneficial Ownership Reporting to support law enforcement efforts. The rule establishes timeframes for legal entities to report beneficial ownership information FinCEN as required by the Corporate Transparency Act (CTA). According to the publication, FinCEN will have rulemakings to: Establish rules for who may access the […]
How do I complete Part II (Amounts and Dates) on a continuing activity suspicious activity report (SAR) if the transaction took place on a single date? Do I include the investigation range from the previous filing?
Answer: The date field in Part II should only cover the date range of activity determined to be suspicious, not the investigation range. If transaction occurred on a single date, the “To” field is left blank. Describe the time period of the investigation in the narrative.
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 […]
New Hemp-related Business Guidance
On June 29, 2020, FinCEN published FIN-2020-G001 providing guidance for obtaining due diligence information for hemp-related businesses. The BSA industry has wrestled with cannabis and its derivative rules since FinCEN’s initial 2014 guidance for banking marijuana-related businesses. Between 2014 and 2018, hemp was equated with marijuana since both are derived from the same plant. However, […]
