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
Legislative and Regulatory BSA/AML Changes
Despite the collective efforts of law enforcement and BSA risk managers across the country, the United States is not doing the best job of finding effective and efficient ways to combat money laundering. Regulatory and legislative efforts, which are the truly meaningful actions that could be taken, are currently being worked on in Washington. A […]
Examiners Stress Independent Audit Critical to BSA Success
On July 22, 2019, the prudential regulators issued FIL-43-2019 making a joint statement on BSA/AML risk-based approaches in examinations. TCA’s BAT reviewed the statement and took away three key points: transparency, risk assessment and independent audit. Transparency – The statement states: “This statement is intended to improve transparency into the risk-focused approach used for planning […]
Quality Assurance Monitoring for BSA/AML Compliance Programs
When your institution is examined for compliance with any law or regulation, the measure of your efforts will be based on your ability to self-identify and self-correct any deficiencies. Ongoing monitoring of key processes helps to ensure that any errors or warning flags are identified early. Monitoring is a required element of a compliance management […]
Model Validations—Why Do I Need a GAP Analysis?
The regulators are upping their game and are becoming more familiar with Automated Monitoring Systems. They are starting to push the boundaries of a model validation and their expectations for a “complete” model testing review. Some examiners are more advanced than others, but the word is being spread and soon they’ll all catch on! This […]
Making SAR Narratives Error‐Proof
Each SAR field is entered into FinCEN’s searchable database, so law enforcement can pull information or run inquires to aid investigations into financial and other illicit crimes. That’s why SARs are crucial. The law enforcement agencies are your audience and they need to know the whole “story” since they were not actively involved in the […]
FinCEN Finalizes New SAR
FinCEN announced updates to the Suspicious Activity Report (SAR) filing format in a notice to e‐filers. The announcement says that the revisions adhere to the changes listed in FinCEN’s February 2, 2017 Federal Register notice and will be live in June 2018. In these new filings, batch submissions will have to be made in an […]
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